We the undersigned trade associations appreciate the opportunity to comment on the North American Securities Administrators Association (NASAA) proposed revisions to its Model Rule on Dishonest and Unethical Business Practices of Broker-Dealers and Agents dated  September 5, 2023 (the “Proposal”).  We collectively represent a broad cross section of the financial services industry, and many of our members do business and serve retail investors, state and federal governments, corporations and institutional investors across the country.

Most of our associations will also be submitting separate comment letters focused on issues of specific importance to our respective members. However, we write to highlight issues
of common interest and concern among our organizations as you engage in your comment review process. Moreover, for the reasons set forth below, we join together in requesting that the Proposal, as drafted, not be adopted at this time.