July 30, 2010
The current suitability standards governing broker-dealers and registered representatives are robust and heavily enforced standards.
Adding additional, unnecessary compliance adds costs in both real dollars and in time, which the client will ultimately bear.
As a state and federally licensed and registered professional, including state life, health and variable insurance, FINRA series 6 and IAR, etc., I am required to undergo significant continuing education and follow other stringent compliance procedures that are more than adequate in ensuring ongoing compliance with these high standards currently in place.
Our office spends roughly 20-25% of our time on compliance-based activities, which would only increase with additional unnecessary fiduciary burdens. The current required paperwork is voluminous and odious. This significantly effects how much time I can spend serving my clients' needs.
If the fiduciary standards for advisors like myself continue to increase, I may be forced to go to a fee-only mode. Going to a fee-only based model would also have significant effects on who I serve, and how well I can serve my clients, as many of my clients would not be able to afford my service, and others would mistakenly believe that they could do better on their own (which survey after survey shows is typically not the case). This could also cause my errors and ommissions insurance to increase significantly, further affecting my ability to serve my clients, and perhaps even cause me to re-think the financial soundness of staying in this profession.
In summary, I urge you to reconsider the need to add additional burdensome and unnecessary fiduciary standards to already well-regulated representatives like myself.