August 24, 2010
Effectiveness of regulations governing broker-dealers and investment advisers.
I am a registered representative and an investment advisor of a registered investment advisor.
I find the suitability standard governing broker-dealers and registered representatives to be robust and heavily enforced. All transactions are supervised by my broker-dealer to make sure they are suitable for the investor. I do not believe the work we do as registered representatives needs to fall under the fiduciary standard under which we function as investment advisors.
I feel strongly that the SEC needs to add additional supervisory staff and procedures focused on Registered Investment Advisors who also act as custodian of the investors' assets. If this had been in place, the Madoff situation would never have been able to become a $50 Billion problem.