August 12, 2010
To whom it may concern:
It is my understanding that you are poised to write new rules authorized by a recently-passed law in Congress that would impose new 'fiduciary duty' liabilities on insurance and financail advisors.
I would like to make the following comments and hope you will give them serious consideration:
#9650 Suitability standards currently governing broker-dealers and registered representatives are already stringent and heavily enforced. Current regulations already provide strong and appropriate consumer safeguards.
#9650 Requiring compliance with 'fiduciary standards' will drive many advisers out of the market and eliminate a valuable advisory resource to consumers, especially in middle- and lower-income markets.
#9650 Additional risk of lawsuits involving registered representatives will increase costs to consumers.
#9650 Driving every registered representative to fee-only compensation will not necessarily result in better, unbiased advice for the consumer.
The paper work involved for taking applications for new securities and insurance products is already cumbersome. Our clients are not requesting additional forms, as they don't understand why all the forms we currently are taking are necessary.