August 25, 2010
I am writing today to express my deep concern over your change of requirement for broker/dealers and investment representatives as a fiduciary standard. As an investment representative of a broker/dealer I am already held to very high standards of compliance both for suitability of the investments I suggest as well as for my actions in the public. As a branch office I am audited by my supervising superior each year at least one time. Additionally my broker/dealer utilizes the services of an outside vendor-auditor to examine my conduct, files and other matters involving my securities business. This is in addition to the required annual firm element training, regulatory training at specified intervals and annual compliance meeting with my firm. All of these matters have drastically increased the time consumed from working with my clients and actually looking out for their individual best interests. It has also drastically increased my costs of doing business. By adding this additional "fiduciary" requirement, which has vague notions of what it actually entails, you will actually be doing a grave disservice to my clients. The existing requirements for holding both my securities licenses as well as my insurance licenses, satisfy any and all consumer protection oversight that might exist. Remedies for any perceived abuses by investment representatives or insurance producers can be adequately addressed under the current requirements. Please do not extend a fiduciary requirement to broker/dealers or registered representatives.