Nowadays, most banks conduct investment sales activities through broker-dealer affiliates registered with the National Association of Securities Dealers. But will it make sense for them to continue doing so? That's the provocative question posed by Robert D. Flowers, president of BA Investment Services, in a Feb. 14 letter of comment to the NASD, which has proposed a new regulatory regime for bank-affiliated brokerages. Excerpts follow:

The adoption of the proposed rule would result in increased costs and regulatory risk (for brokerages and banks) without providing corresponding benefits to customers.

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