August 27, 2010
I am a Registered Representative who offers opportunites for clients to invest in products that my Securities licenses 6 and 63 allow. I have built relationships with my clients through what I offer because I can not, due to limitations of my licenses, charge fees for my services.
My recommendations are based on my clients needs and wants and not on what I can receive in return. I work already for the 'best interest' of my clients. Adding another layer of regulation means another layer of compliance. Already I am examined yearly by my OSJ, need to complete and pass CE programs through my broker dealer through out the year and every 3 years need to pass a course in order to keep my license.
Imposing a misquided fiduciary standard just means that all of my clients could not and would not accept paying a fee for my services. Not that I'm doing a bad job, it's just that their cash flow doesn't permit it. I inform my clients that there is and will be a certain amount of risk in the mutual funds and variable products I offer. They know that in the long run, investing generally results in better returns.
I value my relationships and they value me. Don't ruin what I have cultivated for them to trust me by moving to a fee-only model in order for 'better or unbiased advice'. I work with mostly middle America - meaning people who earn under $100,000 annually. They know that the only way I am paid is by commissions only and to place an 'EXTRA' would keep them away - maybe never to invest again. What would the economic picture of American be if people didn't invest in the companies of America and overseas?
Please DO NOT exercise your authority to impose this misguided fiduciary standard on me and my trusted clients. Thank you.