August 24, 2010
The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. Compare and contrast it to how you see the fiduciary standard governing investment advisers is applied and enforced.
We are an industry that is highly regulated to begin with. This law will only drive up the cost of these products even more. Typically I have an Audit 2 times a year. I spend at least 5 - 10 hours a week making sure everything is compliant and I pay an assistant on top of that. A law like this will only increase the amount of paperwork and the cost of these products. The client will ultimately suffer because due the cost, they instead choose to go without. That is even more of a disservice to everyone. More cost to me affects my business and means I might have to cut costs by letting go of staff. Not to mention the Representatives that will go out of business as well. Our country is having enough issues with unemployment, why contribute to it even more?
Thank you for your time and I truly hope that you think about the overall impact this will have. Please overturn this bill.