August 24, 2010
In my opinion, regulation should begin and end at the broker-dealer level. My broker-dealer, Valmark Securities,has always been compliant to the highest level. Their expectations of us, as representatives, goes beyond what you could legistate or police. We have quarterly examination and reporting as well as case by case review at submission.
I am not naive and realize that not all BD's conduct themselves in this fashion. If the proper policing occurred at the BD level, slipshod practices could be eliminated.
Having 40+ years in the financial services industry and being a consumerist, "best practices" or "best products" are subject to too many variables. All products are no more than tools to meet a specific set of client objectives. If you are developing new rules, the only way to evaluate adherance is the requirement of written, signed objectives against which the advisor's recommendations, compensation, and fiduciary responsability can be measured.