June 27, 2013
I wanted to express my desire that you will not follow through with harmonizing rules between investment advisers and brokers. As the owner of an RIA business, costs will rise significantly with the additional regulatory burden. Current regulation is very sufficient. As a money manager, my business model has little similarity with the sales model used by brokers. The way we are compensated already aligns are incentives with our clients interests.
I believe the principles-based regulatory scheme for investment advisers gives regulators the flexibility to adapt to different business models without constraining those businesses by rules which are really not applicable to their models.
The additional costs and burdens of the additional regulations would hinder our ability to serve our clients and potentially raise their costs.
Please consider all these factors in formulating your final decisions.
Thank you for listening to feedback from those in the investment advisor community.
Scott Kays