Comments on Regulatory Notice 08-20

It certainly makes sense to reconcile the treatment of a civil proceeding filed by a customer with the definition of a “customer complaint”. I think if you just broaden the definition of a “customer complaint” to include arbitration claims, civil lawsuits and similar proceedings, you will capture the information that you seek.

To try and define “involved” will add another degree of subjectivity to an otherwise “bright line” test of when a person is actually named in a civil proceeding. When you’re dealing with someone’s public record, I think you need to be careful and precise.

Neal E. Nakagiri
President, CEO, CCO
NPB Financial Group, LLC
3500 W. Olive Avenue, Suite 300
Burbank, California 91505
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