August 16, 2010
To whom it may concern at the SEC:
I surrender. I'm a Chartered Financial Consultant and am opposed to the new legal fiduciary standard being imposed on broker dealers. After 27 years as a registered representative, I'm forced to become a registered investment adviser and adopt a fee only model. I've always felt like the current broker dealer suitability standard does a better job in looking forward to try and prevent harm to consumers than the adviser fiduciary standard. However, in order to keep up in an ever changing world of compliance, I'm now making the shift to advisory business.
I expect compliance costs to go up, paperwork to increase and will have to hire help to meet the increased compliance burden. Somehow those costs will have to be covered.
Increasing regulation does not change whether I am of moral character with integrity and ethical standards. If I were punk and wanted to do wrong to my clients, increased regulation wouldn't change that. Unfortunately, I'm seeing the onerous increasing compliance standards forcing too many of the "good" guys out of the securities business because they're simply tired of the regulatory headache.
For the sake of other registered representatives who aren't making the shift to advisory business, I submit to you that the current amount of regulation is sufficient. We are already over regulated and the consumers feel it with the amount of paperwork they have to wade through.