ADISA President Michael Underhill sent a comment letter to NASAA in response to its request for comment on Proposed Revisions to its Dishonest or Unethical Business Practices of Broker-Dealers and Agents Model Rule. ADISA’s Legislative & Regulatory Committee Co-Chair Catherine Bowman, The Bowman Law Firm, was the primary author along with Co-Chair, John Grady, ABR Dynamic Funds. ADISA told NASAA that part of its proposal would potentially conflict with or at least expand the language of Reg BI and gave several examples. ADISA suggested that NASAA should avoid conflicts by revising its proposal and use the exact language of Reg BI.

Read the letter in its entirety here.