August 16, 2010
In my practice, I service a number of low to medium income people in advising them regarding their investments. I provide advice to them based upon the suitability of the product to their needs. I am able to deliver this service to them in an extremely cost efficient manner and have a very loyal and satisfied clientele. I am also very closely supervised and regulated through the broker-dealer system and FINRA. In addition, I provide investment management to high net worth individuals on a fee basis wherein I assume a fiduciary responsibility.
If I were to be required to deal with the former group through a fiduciary standard system, I would be forced to switch to a fee-based relationship in order to support the due diligence required of such additional standards. I would be happy to provide them with the same service I currently provide to my wealthier clients, because the remuneration to me is commensurate with the additional responsibility. However, I fear that the unintended result would be:
1. Higher costs to clients who cannot afford them
2. A more complicated delivery system, beyond the scope of understand of many of my less wealthy clients
3. A reporting and administrative system likely to provide more confusion than clarity to the less sophisticated investor
4. A layer of complexity and regulation unnecessary for a less sophisticated segment of the investing public
5. An additional system of rules replacing a regulatory system that is working effectively and efficiently today
Thank you for your courtesy in considering this point of view.