August 16, 2010
Regarding the new suitability standards:
-Suitability standards currently governing broker-dealers and registered representatives are already stringent and heavily enforced. Current regulations already provide strong and appropriate consumer safeguards.
-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.
-Additional risk of lawsuits involving registered representatives will increase costs to consumers.
-Driving every registered representative to fee-only compensation will not necessarily result in better, unbiased advice for the consumer.
In short, I am Series 65 licensed so much of my compensation and everything is already disclosed. In fact, all of my wealth management is done using a fee-based platform. Nonetheless, I don't believe the current steps are going to reduce the number of bad advisors and/or bad products in our industry. Just because you are "fee based" does not mean the consumer is getting a good deal.