Christine Bruenn
Maine Securities Administrator
President, North American Securities Administrators Association

April 28, 2003
Securities and Exchange Commission
Washington, D.C.

I am Christine Bruenn, president of the North American Securities Administrators Association (NASAA); my day job is securities administrator in the state of Maine.

No matter where the averages end up today, I believe this will go down as a red-letter day for American investors. This settlement has the potential to change the culture on Wall Street. If the Street follows both letter and the spirit of this agreement, it will change the way business is done on Wall Street. Investors – not investment banking fees – will come first. And analysts will be beholden to the truth, not the IPO business. On a personal note: what dismayed me most about this investigation was how so many firms with otherwise good compliance programs could’ve allowed this tainted culture to grow up with its systemic problems and exist for so long without doing anything about it.

At the outset of this investigation, we state regulators had three goals – to change the way business is done on Wall Street, to impose meaningful penalties for corrupt behavior, and to arm investors with the facts they need. We believe this settlement delivers on those promises.

While not as important as its impact on Wall Street and Main Street investors, this settlement is remarkable for another reason – I believe it represents a model for state-federal cooperation to benefit investors.

As they did with microcap fraud and day trading, the states helped to spotlight a problem and worked with national regulators on enforcement actions and market-wide rule changes. We’re hopeful that this settlement, that we’re announcing today, will help restore the faith and trust of investors.

There are so many regulators responsible for this settlement. Many are here in this room today – regulators from the SEC, the NASD, the New York Stock Exchange and, of course and most especially, my state colleagues including Attorney General Spitzer. I won’t go down the long list because this could end up sounding like one of those bad acceptance speeches at the Academy Awards – so I won’t name names, but you know who you are.

None of the regulators represented here today could’ve done this alone. There were hundreds of thousands of documents and emails to review and analyze, scores of depositions to take and witnesses to interview. We all worked together, to leverage limited resources and because new market-wide rules were needed to fix this problem the states worked closely with the SEC and the SRO’s. I would be remiss if I didn’t give credit to Congress, specifically the House Financial Services Committee and the Senate Banking Committee, and the SEC for the very important early work they did on this analyst conflict issue in 2001 and early 2002.

Even with their problems, our markets are the world’s fairest and most transparent. I believe this is due in no small part to our unique complementary regulatory system of state, federal and industry regulation.

Now is the time to strengthen, not weaken, this system. Eighty-five million investors – many of them wary and cynical – are looking to us to remain vigilant, to stay the course – to make sure, as I said earlier, that Wall Street follows both the letter and the spirit of this settlement – and that in all other areas they put investors first. We can not and we will not let these millions of investors down.

Thank you.

April 28, 2003