August 26, 2010
I am a registered representative that currently assists many clients with a complete Financial Strategy. It includes very detailed analysis of their current insurance coverage, investment portfolio, debt/liability analysis, health considerations including their financial goals and dreams. Building and protecting my client's financial well being and future is my job. Suitability standards currenly governing b-d's and rr's are already stringent and heavily enforced. Current regulations already provide strong and appropriate consumer safeguards. The SEC wants to hold us to a new legal fiduciary duty that will subject me and any reg rep to never-ending lawsuits, as well as drive everyone to a fee-only model. This will have a profound effect on how my lower and middle income clients are currently served. In effect, my lower and middle income clients whom do not have large financial assets will not be able to afford the costs of a fee-only model. My goal is to eventually offer fee-only services as an IAR to my clients that have a need and have the financial assets and are well-suited to a fee-only model. I am currently required to make suitable recommendations for my clients and it is never one size fits all. I will continue to serve the widows and the orphans, the little people that also deserve a competent professional to look after their best interests, not just cherry pick the rich or wealthy individual that fit the ticket for the fee-only model. I also have broker/dealer and investment product oversight and scrutiny on every single investment transaction and recommendation I make. I have continuing education requirements, ongoing weekly training, six full days of investment/suitability related training and monthly investment product updates that I personally attend to stay on top of the everchanging investment environment. I am an informed valuable resource to my clients and the compliance with fiduciary standards will cause additional risk of lawsuits involving reg reps and myself with an increase of costs to consumers. If there are loopholes in the current environment or process, let's fix them. Driving every reg rep to fee-only compensation will not result in better, unbiased advice for the consumer.