July 28, 2010
I am submitting my comment so that the policy makers reflect on all real issues behind the Fiduciary Trojan horse.
I have been registered in our financial markets since 1984 and have traded for both principals and clients. Since 1984, broker dealer business structures have changed, banking affiliations and laws have changed and business competition has been intense. Yes, I believe the Fiduciary Standard is really about the survival (Anti- trust) of our two major business structures (the Broker/Dealer Model and the Investment Advisor fee base Model).
I don't believe the United States of America nor other world Capitalizations could have been built following a Fiduciary Standard. Free enterprise does not always follow fiduciary standards and to force one business model to follow such standards could jeopardize our entire financial structure or at lease eliminate fair competition between the business models. This has lead to the commoditization of our financial products and eventually our financial advice. I can't imagine how an investment banker /broker could be efficient bringing an Initial Public Offering , as a Fiduciary, without immense business legal liability. Shall we paint Legal targets on the backs of half of our registered businessmen?
Let us work together to protect and disclose for our clients, but not destroy entire business structures that are directly responsible for the success of modern Capitalism in the first place. Competition is not broken, so don't fix it. This is about Anti-Trust