August 26, 2010
I would like to post an observation that hopefully can help you to understand the potentially devastating impact of your proposed modifications to the current suitability standards imposed on broker dealers. First of all, the majority of investment advisors work with integrity to advise clients to allocate their funds in the most appropriate manner. While there have been numerous cases that have surfaced in the past few years, the majority of these cases have involved unscrupulous practitioners who have been out to defraud the public. Better inforcement and oversight of the current standards are needed, not some ambiguous fiduciary standardsa that will leave the door open for a flood of business-clogging lawsuits due to the vague liability standard proposed.