August 26, 2010
Please consider these things when thinking of changing any rules. The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients. I have a series 6 liciense and have office audits every other year and when I write a variable annuity or mutual fund if the required forms do not show enough liquidity we have to prove how they qualify for this product. I have trouble getting enough information on forms to satisfy our compliance dept., if I had to get more my clients probably won't be investing. As this drives the cost up with more regulation, will this really protect the client more or just cause him not to save? I believe it will be the second and with the ecomony as it is this is not a good idea Thank you for the opportunity to give you my thoughts.