August 24, 2010
Ladies and Gentlemen:
I cannot support your intentions of imposing another layer of compliance regulations on me as a register representative. I am already adequately scrutinized by my broker dealer to the point where I must spend hours of my time in required CE classes, anti-money laundering tests, mandatory registered representative retesting, etc., etc.
To add another layer of unnecessary oversight responsibility to the SEC's already under staffed and over worked employess will accomplish little, if anything positive.
Lastly, the preception that the legal fiduciary duty governing investment advisers provides greater investor protection than the suitability standard governing broker-dealers is misguided and totally unnecessary.