August 24, 2010
In my opinion there is no change needed in broker dealer oversight to the fiduciary standard. The suitability standard currently used by broker dealers and registered representatives is a strong and heavily enforced standard. There are strict rules of complience that must be adheared to by all registered representatives. Registered Principles visit the registered representatives at least quarterly to review standards for suitability. All applications for financial and life insurance products are closely scrutinized for suitability by home office staff and any potential sutiability concerns must be addressed and overcome befor the application continues to underwriting.
I do not feel that a change in the name of or type of complience and oversight will add to consumer protection in any regard. Any change in the standard will likely only add additional costs to companies, registered representatives and ultimately, to consumers. These costs are avoidable and unnecessary.
Thanks for your condsideration in this matter.