August 24, 2010
Today, The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. Compare and contrast it to how you see the fiduciary standard governing investment advisers is applied and enforced. Compliance costs money-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 currently have a series 6, 63, and 26. I have an annual office inspections, I do Annual Office inspections, anuual CE credits, Annual Firm Element, once every 3 yrs regulatory element, Annual compliance meeting, and Annual compliance questionair.
I spend on average 120 hours per year completing compliance issues. We spend more time on compliance than help clients
The addtional liabilities of a fiduciary duty will mean higher costs and will reduce my ability to serve my clients.
I don't think our clients can afford to pay the up front fees nor will they be willing to do so
The increase liabilities will drive up your errors and omissions coverage
This will force several registered reps out of the business Too much Regulation is just as bad as not enough