August 17, 2010
RE: File No: 4-606
Dear Ms. Murphy:
I have held the Certified Financial Planner® professional designation for 23 years and the Certified Investment Analyst® professional designation for 13 years. I currently serve as an investment adviser representative for a registered investment advisory firm with $15 billion of assets under management.
I strongly urge you to extend the Advisers Act fiduciary standard of care to ALL financial professionals who provide personalized investment advice to retail clients.
Consumers cannot adequately judge the quality of investment advice provided by an advisor based primarily on the advisor's registration or title. Such circumstances frequently prevent consumers from knowing whose best interests are being served - theirs, the advisor's or the advisor's employer.
Adhering to the fiduciary standard of care and putting clients interests first benefits the investing public as well as all ethical investment advisers. Adhering to the fiduciary standard of care will not limit advisers in their ability to provide clients with appropriate services and products, irrespective of the clients level of wealth. What is paramount is disclosing, avoiding and/or fairly managing any and all conflicts of interest.
I urge you to recommend that Congress extend the fiduciary standard to broker-dealers, who provide personalized investment advice.
Robert E. Fletcher, CFP®, CIMA®