July 30, 2010
I am concerned about the effect the Dodd-Frank bill is about to have if the SEC takes yet another step to over regulate investment advisors through a "fiduciary standard." Wording such as "best offer" and other vaguely veiled attempts to invoke protections through a "standard" will only cause more paperwork, less ability to service clients, and reduce what Broker-Dealers / Advisors can safely offer clients in terms of choices. Such wording will also produce numerous more frivoluous lawsuits when a client simply is unhappy, thus causing advisors to pay through the roof for liability protection. That in turn will escalate the cost to clients for all services. All of this is unnecessary.
In addition, class "C" shares are under attack once again. Do you realize that many clients suffer when they are made to pay front loads or surrender charges in products they do not keep very long? More and more advisors are turning to either no load or "C" type products to give flexibility to certain clients whose needs may change quickly.
Please instead protect us from this escalating regulatory environment, or you will damage the advisory industry forever and only the "big wire house types" will survive. That is not in the public's best interest.
Please avoid adding ANY more regulations on advisors. Punish the true violators and find ways to HELP those who of us do it right