August 9, 2010
The suitability standard governing broker-dealers and registered representatives is already a robust and heavily enforced standard we do not need another layer of compliance. The current regulations should be enforced.
Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.
We already spend at least 5 hours a week handling compliance items some of which do not add any consumer protection in my view.
An additional level of compliance for fiduciary duties will increase the cost of our E O coverage and our ability to serve our clients. Clients will bear this cost in terms of additional fees.
I strongly urge you to not pass additional regulations for broker dealers and registered reps.