August 25, 2010
I am writing regarding the proposed fiduciary standard to be applied for all broker dealers. I feel that this standard is unnecessary, as we already act in the consumers's best interest. This new regulation would impose a vague and confusing new standard, that would lead to more lawsuits from the trial lawyers. I can't imagine paying even more for my errors and omissions coverage. If a fee only platform becomes the "acceptable fiduciary standard", what are clients to do that can't afford or simply won't pay the fee?
I have been in the insurance and investment business for 26 years. I have continued to improve myself by obtaining the CLU, ChFC and CLTC designations. This knowledge helps me help my clients to obtain the best solutions to help them reach their financial security. Our office has hired two full time compliance officers and our emails and other correspondence are reviewed daily. We have face to face reviews at least once a year. All investment trades and insurance recommendations are reviewed either locally or at the home office. Adding another level of compliance is unnecessary and probably, more costly to the clients.
I hope you will reconsider and drop this proposed legislation.
Patrick C. Robison, CLU, ChFC, CLTC