August 9, 2010
I am against the proposed regulations to have registered representatives adhere to fiduciary requirements. Registered representatives are already highly regulated and did not contribute to the crisis that has recently befallen our economy. The downturn in the market and the present economic crisis was not the result of registered representatives abusing their trust, but was the result of unregulated and speculative sophisticated investment instruments with which the ordinary registered representative had little if any knowledge, much less advised any of his clients to purchase.
Registered representatives are already held to high suitability standards designed to protect ordinary investors. We already spend an inordinate amount of time dealing with compliance issues. I had to hire a full-time assistant to take care of paperwork dealing with compliance. I hold the insurance license, the series 7 and 66. Each license requires costly continuing education course work, license fees and examinations. All of these compliance requirements take time and cost me time away from dealing with the needs of my clients.
If you require registered representatives to migrate to a fee-only basis, it will not lower the cost of investing, but will actually increase it.
Please reconsider implementing these new stringent and burdensome regulations. They will only succeed in increasing costs while lowering service to the consumer.