September 6, 2010
I hold a life, health insurance licenses, and var. Annuity and Series 6, 63 and 7 securities licenses. I an examined annually. I spend at least 20% of my working time on compliance, such as mandated state and federal compliance already. It is extremely burdensome and inhibits my time to earn a honest, echical and trust worthy living. More than 50% of the paperwork is compliance related. Many of the reporting requirements do not help the client better understand the securities sold nor do they add value to our relationship and mutual understanding of the clients needs. The service to muy clients is severely impeded by extra forms, and time lag between extra requirements that have been made. Moving to a fee base only system will not help our clients nor increase sales of securities in an honorable manner. If I am forced to a fee based model only, I may be forced out of the business. My liability has been greatly increased by all the compliance regulations you and FINRA have added to my business. My clients pay less on a up-fromt commission that reduces below the fee based model after the first year. We are adding extra expenses to our clients with the fee based method of compensating Reg. Reps. My risk of EO claims has increased and the cost of the insurance has skyrocketed out of reasonable sight.I will not stay in the business if these compliance issues increase and the expense of the EO insurance continues to increase.
Sincerely, Frederick L. Krempin