August 27, 2010
I am ultimately concerned about my clients in regards to your proposed changes.
I am licensed as an investment adviser, and can do fee-only planning.
However, a vast majority of my clients are modest in means-- and are not be able to participate in a fee-only model. If this legislation/rule change occurs, an UNINTENDED CONSEQUENCE may be that modest-income Americans lose the resource of quality service and advise.
I am surprise-inspected by my broker-dealer once a year, and by my company at least once a year. I am a sole-proprieter, and already employ one full time employee to deal with compliance reporting and rules. The cost of regulation gets passed along to clients ultimately.
While the intent of your rule is to protect the public, it may instead cause the public to loose access to quality Registered Representatives who are already working in their best interest. These rule changes may mean I can afford to work only with wealthy clients.
I urge you to enforce the rules you have already. The proposed changes will not stop the Bernard Madoffs of the world. What they may do is to cause middle-income Americans to loose access to quality advise and products.