August 30, 2010
To Whom It May Concern:
I am writing to encourage you to consider the "suitability standard" when governing broker-dealers and Investment Advisors. The suitability standard is a forward looking approach that best helps consumers and the advisor community. Applying the "fiduciary standard" could be damaging to the consumer and the ability of the broker-dealer and advisors to effectively help their respective clients.
Advisors and broker-dealers are already heavily monitored and regulated. We spend multiple hours and money to meet compliance standards, practicing due diligence, and covering liability issues. The proposed "fiduciary standard" would only add the the cost and burden of doing business with adding no real benefit to the consumer as it is a vaguely defined standard. What is "best interest" of the consumer? Lowest cost? Highest rated company? Best customer service? This standard will only add regulation and to the legal liability and therefore the cost of doing business. This extra price is always passed on the consumer.
Thank you for your time and interest.
David Lucas