August 17, 2010
I believe that you are imposing a misguided Fiduciary Standard on Registered Representatives. Registered Representatives are regulated enough. I disagree that the fiduciary standard has protected consumers better. Basically, the fiduciary standard looks back and enforces breaches retroactively through SEC enforcement or private lawsuits. The suitability standard looks forward and tries to prevent harm to consumers through ongoing and frequent FINRA and broker-dealer audits and compliance processes.
Compliance cost both in terms of finances and time are high, and those costs are eventually felt by clients. Thus adding another layer of regulation means another layer of compliance, and even more cost to clients. We are examined every two years and the amount of time and paperwork increases significantly with each exam. Please do not impose this Misguided Fiduciary Standard on Registered Representatives.
Thank you for your consideration of this request.