July 30, 2010
I am a 28 year FINRA Series 6 and 63 licensed financial services representative, licensed also for Life Insurance and Annutites, Sicness, Accident and Health, and Property Casualty Insurances. I have always been affiliated with a Broker/Dealer that holds me to a high standard to make sure that what I do is always in the best interest of my customer. I feel strongly that the current regulations in place that govern my actions are sufficent to safeguard that sacred trust, and that the new regulations you propose are not only redundant, but could be harmful.
You propose to regulate me like an investment advisor whose level of regulation far exceeds the scope of my current licensing, clentelle, and need. This additional regulation may be just enough of a nudge to force me from the securities industry altogether which will only serve to harm rather than help my customers. I already spend more each year to maintain my licensing for the benefit of my customers than I make in compensation. If I were the only one who would react that way, I could see a cavalier attitude on your part feeling you'd done your part to protect consumers from someone who is perhaps not prepares as well. But the reality is there are thousands of me out there and your proposal would serve to orphan a lot of people who rely on us to guide them.
In conclusion, I urge you to leave the current system of regulation in place. The current system works. Your proposal would raise the cost of doing business, would be redundant, and is likely to do more harm than good for the customers you seek to protect.