July 30, 2010
I understand, respect and appreciate The SEC looking after the best interests of the American Public (since my family and I are surely part of that demographic), nonetheless, this particular piece of proposed oversight would be costly to firms, individual advisors of those firms, and therefore, the clients, as these additional costs would be passed on. Clearly, recent events suggest that oversight is very important as unethical "Advisors" have stained the industry and made it harder for truely caring people to build trust with the public. Unfortunately, many of these people were of high intellect and stayed outside the scope and view of regulation, this proposed reg would not have dissuaded them.
I believe the SEC is studying the possiblity of additional oversight with good intentions, but speaking for myself and others around me, I can assure you that my company's internal Standards and Compliance department is thorough and stringent, as I believe most large firms are, if not in the past, certainly now. If anything, it is the "lone wolf" producer, attached to independent Broker/Dealers or none at all, who need additional scrutiny. The thousands of people working for very large firms where Firm Element meetings and systematic unannounced inspections are done seem to suffer undue attention while the "small, almost-unseen" producer operates without regulatory structure.
I oppose this additional obligation as extraneous, costly and hurtful to the general public.