August 24, 2010
The existing suitability standards governing Broker-Dealers and Registered Representatives are already very stringent and heavily enforced. I currently have to do 30 hours of continuing education every 2 years to maintain my Life insurance licenses which include 3 hours of ethics courses. I need to complete at least 3 courses of continuig education every year to maintain my Registered Representative appointment. These courses always include suitability standards for dealing with clients.
I currently have to submit client signed documentation regarding suitability for each and every case I place. My business practices are reviewed on site every year to make sure I stay compliant with all of the rules and regulations.
I can understand why there may be a need for more stringent requirements for "Registered Investment Advisors" as many of them are not Registered Representatives and do not fall under a strict supervisory set of rules.
Please consider my thoughts in making your recommendations as the cost of doing business is already very high with the existing requirements that I must abide by.