August 24, 2010
I'd like to impress a few of points on this primarily as I feel we as registered reps are already regulated more than sufficiently
1. The current suitability standard governing broker-dealers and registered reps is already a robust and heavily enforced standard. I'd like to see you compare and contract how you see the fiduciary standard governing investment advisors being applied and enforced.
2. Compliance has a cost factor associated with it and by adding another layer of this, would only mean that ultimately the client would suffer. I have my 215 license, Series 6, 63 and 7 and between them all, I am constantly being examined and having to keep up with my compliance requirements. We have an in house compliance officer who we see on a regular basis who holds us to all of our compliance requirements.
3. The liability of having a fiduciary liability will increase my osts, waste more of my time with clients and ultimately hurt my clients. Will I have to go to a fee base service? Will my costs go up and ultimately my clients? Will my EO go up? Ultimately will this put registered reps out of business?
I asked you to look at all these points very carefully.
Sincerely,
David Walter.