August 24, 2010
I am writing to oppose the consideration of an imposed fiduciary standard on broker dealers and registered representatives. As a RR serving my clients and community I value the extended relationships with have with our customers that literally span several generations of thier family. By working with our clients and helping them understand their investment choices and coming up with a suitable option for them, we both have a clear understanding of where they stand and where they wish to go. Behind the scenes, they have no appreciable understanding of what is required of us as Registered Reps, from the licensing classes to the compliance meetings. But during our discussions and planning it does not matter...for they are matched with a product that they find suitable. These standards are already strictly adhered too and allow us to refer back to the decisions made by the client at the time of the application well into the future. We act with our clients with that relationship in mind, as it will be us sitting down together years into the future reflecting on their needs. By imposing a fiduciary standard on us as RR, this will have a negative impact on how we serve our clients as the standards become less clear. In addition, I believe that other agents that serve to accomodate their clients by offering their services as a RR will decide that the fiduciary standard is too intimidating and exposes them to potential legal action that does not make this service worth the risk, thereby limiting the service they can offer their clients.
Please maintain the suitability standard and Do Not impose a fiduciary standard. Thank you