August 26, 2010
I am a 39 year veteran in the financial services industry. I will be retiring within a year, so any impact regulation changes may have, will be minimal to me. However, I want to speak for a system that I feel is working very well. The current suitability standard as enforced by my company requires me to do an in depth study of each clients current needs, goals, risk temperment, and future objectives. It is required before submission of new business, and updated each time an additional investment is made. If the company finds something that seems inconsistent with goals, risk temperment, etc. they will call and discuss the issue with me. As you are aware, this type of accountability by registered representatives has not always been there. But, now it is there and strictly enforced. It places the responsibilty of keeping the clients interests foremost squarely on registered representatives and the companies they represent. This system works, and deals with the need for responsible recommendations prior to investment by the client. Placing a fiduciary standard on registered representatives will be less proactive for the consumer and more burdensome for the registered representative than continuation of the suitability standards we now work under. For the sake of those who will come after me, please do not add this additional layer of regulation to a system that is alive and well.