August 16, 2010
Please take into consideration what is being proposed regarding current regulation. 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.
Please think of this from the average new family wanting to get started making sound financial plans and don't have a lot of money or knowledge about how to get started. If they try to research basic financial planning on the internet or by looking at a library, they can find a plethora of good information. Unfortunately the feeling of understanding and trust in simply reading about what to do is not the same as hearing what to do from a professional who has studied, trained, and continued to educate themselves who can be a resource for continued service and questioning when needs change and fear of not understanding come into play. Without this trusted person to rely on, implementation of basic necessary financial planning is not as likely. This is important to the financial health of our citizens and the health and future growth of our country. Fee-based only compensation will make it more expensive to the consumer and less profitable for the advisor which would push many advisors to another profession leaving the under served public with very few expensive advisors to turn to when trying to make basic financial planning decisions.