August 30, 2010
Wachtel Co., Inc. is a very small self-clearing, full service broker-dealer -- regrettably, one of the few left in the industry.
We have no position on whether a fiduciary standard should be adopted for broker-dealers. However, based on the experience of this firm, we believe that our clients would receive no benefit, because our practices are almost entirely in line with such a standard.
Like other responders, we are extremely concerned that a substantial regulatory burden (like registering under the Advisors Act) would follow with the decision for change. We all know that regulation is high in this industry, but more importantly: most increases in regulatory burden are DISPROPORTIONATE to small firms, who have less revenue over which to spread the cost.
We strongly urge that an expedited and easy path to compliance be provided -- particularly for small firms -- should the new standard prevail.
Thank you for the opportunity to present these comments.