August 30, 2010
Fiduciary standard. I already take a high regard to care with my clients. If you impose this standard with my clients I will be forced to go to a fee only model. Many of my moderate income clients use my services because I don't charge a fee. By imposing a fiduciary standard it will drive up the cost of services to the very people I service and you claim to protect. Besides, my broker dealer already does a significant amount of work in making sure we do what's in the best interest of the client.
Licenses. I hold a life, accident health, state and federal securities license, along with a number of professional designations. I spend at least 20% of my time on compliance related issues every week. Adding any more to this will only cost my clients. As an example, a recent life insurance application was 46 pages in length, and required a number of disclosures. At the rate our industry is headed, that will continue to increase and I may have added expenses that will have to be paid by my consumer clients.
Consumer clients. Regulatory reform should be designed with a common sense approach. Consumers who do not have the where with all to buy a home should not have been given the opportunity to buy a home. Those are renters. My consumer clients desire to own a home but have established appropriate savings plans with the goal of home ownership. Doing it right as opposed to doing it expeditiously. Helping clients gain financial knowledge will only help them for a lifetime, a fiduciary standard does not do anything for knowledge, just adds expense and layers of cost not necessary. Consumers are the ultimate payors for these costs and I have had no clients say to me that they are willing to pay more for the same level of service or care they are provided to by my work.
Please take these comments into consideration as you look to the future.