Comments on Regulatory Notice 08-20

Greetings,

Member Firms could arbitrarily abuse this revision to recover losses related to the claim from the RR and/or make his value on the street less desirable.

It may be better to allow the arbitration panel or another independent, objective and unbiased third party determine if the RR should be reported.

This proposed rule change appears to create more potential for abuse problems than it remedies.

Regards,

Paul C. Spitzer
Senior Vice President
Wachovia Securities, LLC
11682 El Camino Real, Ste 110
San Diego, CA 92130
858 523 7999 direct
800 538 8301 toll free
858 523 7997 fax