August 27, 2010
The suitability standard govering broker-dealers is a heavily enforced standard. I hold insurance licenses and am a registered representative. I have CE requirements for both. I have a office exam twice a year and currently spend at a minimum one hour per client on compliance paperwork. By requiring that all broker dealers and registered reps be held on the same legal fiduiary requirement as investment advisors would NOT provide greater investor protection than the suitabilty standard governing broker dealers. By adding another layer of regulation means another layer of compliance, and even more cost to clients and impact my ability to serve my clients. I work with small and middle income investors who would not seek advice if thay had to pay a fee so, would moving to a fee only model result in better, unbiased advise? NO. I believe I am already acting in the best interest of my clients. I'm not in favor of any change and feel if there is it would increase my liabilities, drive up my errors and omissions coverage and I may not be able to stay in business to serve the many cients that depend on my advise. Mark E. Oboy, LUTCF