August 23, 2010
In response to the proposed legislation on obligations of brokers, dealers and investment advisors, I would like you to know that the 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. Also driving every registered representative to fee only compensation will not necessarily result in better, unbiased advice for the consumer. We have many clients that put a minimum amount of money away each month, just to save "something". Charging them a fee for this service would not only not be fair, but would eliminate this socioeconomic market from saving for their future.