July 30, 2010
Please do not impose an additional fiduciry standard on me and my financial services practice as I believe that as a Registered Investment Representative I am already regulated enough.
The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard.
As a CFP I am already conducting my business as a fiduciary and my license to use the CFP mark is contingent upon my compliance with this standard now and in the future.
Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.
I already have to go through several periodic compliance audits every year for my broker dealer. This new proposed regulation (fiduciary standard) is duplicative and will not add to consumer protection in any meaningful way.
Furthermore, as the time and cost of compliance and government regulation continues to esculate it may actually drive many representatives out of the business, leaving fewer representatives to serve a growing market of consumers. This shortfall could easily lead to inconvenience for consumers and possibly to additional fees to obtain the services desired from qualified representatives and advisors.
This additional regulation could also cause a significant increase in my errors and omissions coverage which I would most likily have to pass on in the form of increased fees to my clients.
Thank you for keeping the "suitability standards" in place and not adding additional compliance regulation (fiduciary standard).
This new standard may create an additional barrier to new representatives intering the business in the future. This could add to the public being under served by the industry in the future as the current community of Registered Representatives and Financial Advisers are aging, with an average age of the most successful representatives well over age 50.
In the mean time, thank you for your efforts to strike the correct balance between protecting consumers and respecting the market place.