August 26, 2010
I am writing to you because I am concerned about an upcoming change in rules that is being considered that would hold all financial services professionals to what is known as a fiduciary standard in all dealings with clients. I believe that such a change is inappropriate and will not best serve the interest of the clients with whom I deal, as they are overwhelmingly in the middle market. In addition, as a registered representative
I would be in a position where there would be a conflict of interest, since as a Registered
Representative working for a Broker Dealer I am required to act in a fiduciary capacity on their behalf.
As you are no doubt aware, to offset this conflict I am held to what is known as a suitability standard, to which my broker dealer requires that I rigorously adhere. Through suitability standards I am required to assess financial resources, risk tolerance and investment objective of prospective and existing clients, and in so doing try to achieve the best fit between client and investment or insurance product.
It is my opinion that introducing the fiduciary standard would do absolutely nothing
to benefit my clients, and in many cases potentially cause harm, since many of my clients are of modest means and would not be willing or able to pay the advisory fees that would then be charged in lieu of current compensation that I receive from the broker dealer. I believe this would be the case with the vast majority of retail investors and insurance clients that I and my many colleagues serve, and thus must strongly advocate that no such change in rules is required.