August 24, 2010
I am writing to you today to ask that you not proceed to impose the onerous rules on broker-dealers and their registered representatives that are contained in the Dodd-Frank Wall Street Reform and Consumer Protection Act that was recently passed.
The current standards that govern their activities presently are both robust and effectively enforced. At present, the time and expense of compliance are high enough that some high quality advisers have chosen to leave that area of our profession, in order to focus elsewhere in order to serve our clients, while earning a reasonable living. The requirement to be every ready for compliance visits from OSJs to other inspectors, in addition to the Department of Insurance, leads to issues such as file duplications, and separate locked files for clients with registered products. In most cases, the adviser must add staff personnel to handle compliance issues, the expense for which is an added burden in office space and expense.
The people who are most likely to leave the profession, or even just the product field, are those who work with the middle income and even those at the low end, who see the necessity to plan ahead, and to accumulate retirement money of their own, and not rely solely on Social Security, or even employee benefit retirement plans.