July 30, 2010
In my opinion the fiduciary standard is not what the financial services industry needs today. The suitability standard does a much better job of balancing the public interest as well as treating the financial services providers fairly. Any standard that is based on hind site is not fair treatment for anyone. I am a financial services professional with series 6, 63 and 65 licenses. I'm not a trader, I do planning for my clients long term financial success. I use very low expense front end loaded mutual funds with an established successful long track record. I believe that the fiduciary standard will force me to fee only management. That change will at least double the fees my clients will have to pay for no reason. I believe it will also increase my administrative costs significantly. At the present time my assistant spends the majority of her time making sure we are compliant with everything we do. At least quarterly I'm required to do some form of compliance testing and training at my own expense. With the increased requirements and costs of the fiduciary standard, the time I spend with my clients and their investments will be reduced and my expenses will increase. I have been providing financial services for clients for 33 years without ever having a complaint or ethics charge. These new regulations will put an additional burden on me and my clients. I believe it will force many good providers out of business. There will always be a few unscrupulous people in every industry. They will find a way to operate no matter what the law is. More rules and requirements are not always better for the majority of the consumers. Please keep this in mind before adding another layer of regulation and expense that will only reduce the returns of America's savings.