August 24, 2010
I beleive that the suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. It seems completely unnecessary and counterproductive to impose a new fiduciary standard governing investment advisers.
Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients. I already am highly regulated through my own company, the states I am licensed with and through FINRA. We already spend an enormous amount of time on regulatory and complaince issues with overwhelming paperwork much of which does absoluetly nothing to help the consumer. Why add more unnessary papework and hurdles that will NOT help the consumer and make our lives even more difficult.
My expenses and efforts to maintain my practice are already taxing beyond what seems reasonable. I lost two colleagues in my office this year already because they simply couldn't make financial ends meet in part because of the heavy compliance and regulatory environment that eats away at so much time and reduces our productivity possibilities.