NAIBD COMMENT 09-22 FINAL




June
4,
2009 

Marcia
E.
Asquith 
Office
of
the
Corporate
Secretary 
FINRA
1735
K
Street,
N.W. 
Washington,
D.C.
20006 ‐1506 

Re: 
 Regulatory
Notice
09 ‐22

 
 Personal
Securitie s
Transactions 

Dear
Ms.
Asquith: 

The
 National
 Association
 of
 Independent
 Brokers ‐Dealers,
 Inc.
 (NAIBD
 or
 the
association)
was
formed
in
1979
to
positively
impact
rules,
regulations,
and
legislation
by
facilitating
a
consistent,
productive
relationship
be tween
industry
professionals
and
regulatory
organizations.
The
organization
is
national
in
scope
with
350+
Broker ‐Dealer
and
Industry
Associate
Members. 

NAIBD
appreciates
the
opportunity
to
comment
on
the
proposed
rule
noted
above.
We
hope
that
our
expres sed
views
will
have
constructive
value
in
presenting
alternatives,
issues
and
concerns
regarding
the
new
rule
proposal,
and
that
our
responses
to
specific
questions
posed
in
the
Regulatory
Notice
are
informative. 

NAIBD
recognizes
and
appreciates
the
exten t
to
which
consolidation
of
the
NYSE
and
NASD
rules
presents
efficiencies
and
overcomes
outdated
language.
In
particular,
the
proposed
elimination
of
NASD
Rule
3050(a)’s
requirement
regarding
account
opening
due
diligence
and
the
elimination
of
the
specifi c
supervisory
requirements
of
NYSE
Rule
407(b)
positively
reflect
the
overall
efficiencies
resulting
from
the
 consolidation 
of
the
rulebooks. 

Notwithstanding
this ...