August 27, 2010
I am a registered representative holding a Series 6 license. I am very much against the concept of the SEC imposing a legal fiduciary standard on broker-dealers and their registered representatives for the following reasons: 1) due to the costs by adding another layer of compliance will result in these costs being passed on to clients perhaps with front-end fees. 2) my EO liabiltiy insurance premiums will undoubtly increase due to the increased risk of being a fiduciary. 3) Borker dealer costs will increase due to the added compliance visits which I'm certain will be passed on to investors. 4) I may be forced to stop selling mutual funds and variable products which will force me to retire and many others to leave the business which already is having difficulty finding good representatives to serve our population.
It is my opinion that Suitability requirements already inforce provides sufficient accountability and enforcement of current regulation. I feel my broker-dealer does a very good job in assuring our compliance to current regulation and of the services we provide our clients.
It is for these reasons that I truly hope the proposed Fiduciary Standard governing investment advisers is not added to an already very governed and heavily enforced standard.