Subject: Study Regarding Obligations of Brokers, Dealers, and Investment Advisers 4-606

August 25, 2010

Dear SEC

I have been in the financial services business for over 30 years. Twenty Three of those years was with AXA-Equitable as an agent and manager.

I am now an independent advisor and insurance broker working with a small BD and I am extremely happy to be away from a corporate culture that is simply not working..

What has and continues to be a thorn in my side is all the confusion consumers have regarding who does what, why and for how much.

The wire houses like Merrill, UBS, Morgan, to name a few seem to be only interested in Investment Banking and not the retail consumer.

The Insurance company BD’s only care about selling their proprietary products under the guise of “Financial Planning”.

The Financial Planning Association (FPA) is doing everything they (we) can do to improve this environment for the consumer, however the SEC and other regulatory bodies need to do the same.

This outreach for comments is exactly what needs to be done first.

Every person who works as a front line professional , whether they give advice or not needs to be regulated the same way, in my opinion.

I always found it amusing, if not downright wrong, at Equitable, when we began to sell Mutual Funds and Variable Life, that we were told “We don’t give advice” . Tell your client when you want to sell him something; “I suggest you consider this fund”.

This play on words cannot be allowed in the ethical environment we all want (I hope) because that sales person can get away with much more than I as an advisor can and mislead the public as to what his true job is.

No matter how you slice it, whether giving advice or suggestion for consideration the differences are too subtle for the average investor.

Too many are getting away with far too much and consumers don’t even realize it.

It’s not about being able to get away with anything, it’s about having a playing field that is fair to the consumer. At the end of the day it’s about protecting the consumer by having honorable and ethical people providing financial advice and services.

That is all I am saying. Make the rules fair and enforce them.

I want this enormous misrepresentation problem that is everywhere to stop.

Let’s focus on what is truly important and not discourage all the good people doing a good job.

When I see clients come to me from other firms wanting to transfer their money due to generally poor service I am always dumbfounded by how little they know about what they are paying in fees or commissions or both. How they came to developing the asset allocation and holdings of their accounts and the fact that they were not told this clearly enough that they remember.

In fact quite often their reports show no expenses related to the broker/advisor.

I welcome anything the SEC can due to better our industry.

Let’s hope our politicians can do the same for our country.


Leon Rousso, CFP®
Leon Rousso & Associates