August 25, 2010
A careful study of the regulatory environment as required by the Dodd-Frank legislation will reveal the following:
1. Broker Dealers and their representatives are already forced to comply with a plethora of regulation which very adequately protect a consumer's interest.
2. The cost of complying with the existing regulations is significant. Adding another layer of complexity to these regulations will be cost prohibitive and will likely compel representatives serving middle markets and small businesses to give up there Registration or significantly increase their fees.
3. The "best interest" criteria is too vague and to hard to enforce. The current standard of "suitability" is more than sufficient.