We strongly recommend that variable contracts be exempted from any subsequently approved rule. Local Office Definition Particularly troubling is the introduction into regulations of the broad definition of local office which would include any location where two or more associated persons regularly conduct a securities business. In our case, it is estimated we would have approximately 150 two person offices. These offices are ever changing either by location or the addition or subtraction of an associated person. One must remember that many two person offices are minimal producers and are engaged in either fixed insurance product sales or variable product sales.
Provision is made for electronic recordkeeping and for same day production of records.
We would suggest, should the current proposal survive, that the same day requirement be extended to three business days to allow for either electronic downloading or overnight mail services. A state depository is proposed for a one person office. We question why such a system should not be made as an alternative to the local office retention requirements. Where an associated person is assigned to a branch for supervisory purposes, then the required books and records would follow that system. We believe the current proposal is unnecessarily burdensome in light of costs and any benefits to be derived.