August 24, 2010
I'm writing concerning the recently-passed Dodd-Frank Wall Street Reform and Consumer Protection Act.
I'm a member of the National Assn of Insurance and Professional Advisors (NAIFA), the CFP Board of Standards (CFP Board) and a FINRA Registered Representative RIA.
Most of my 23 year career in the financial services industry have been primarily as an insurance agent who offers variable fee based investments.
Based on my career experience, requiring all broker-dealers be held to the same legal fiduciary requirement as investment advisers would be overkill. On this topic I DISAGREE with the CFP Boards call to impose the Fiduciary Standard on all broker dealers. In my everyday work abd as a CFP - I find not all investment clients want, need or can afford fee based planning.
The sutiability process used by registered representatives is a solid process, as solid as the back office of the broker dealer who enforces it. I encourage you to enforce the regulations currently in place and not add an additional layer of regs that will ultimately cost the consumer more.
Respectfully submitted,
David J. Grantham, CFP
Bradenton Insurance, Inc.
1400 Ballard Park Drive
Bradenton, FL. 34205