July 30, 2010
I am a Registered Representative and do advise clients regarding financial matters and investments(Mutual funds). I feel that the current FINRA oversight of my broker dealer and myself is effective. I do NOT believe that the legal fiduciary duty governing investment advisors provides greater investor protection than the suitability standard governing Broker Dealers. The fiduciary standard has not protected consumers better. The fiduciary standard looks back and enforces breachs retroactively through SEC enforcement or private lawsuits. The SUITIBILITY standard looks forward and trys to prevent harm to consumers through ongoing and frequent FINRA broker dealer audits and compliance processes. I already act and conduct business in the BEST INTEREST of my clients. Your vague definition, of best interest..., surely will expose everyone to never-ending lawsuits. I am over-regulated currently If fiduciary duty prevails, I cannot promise that I will be able to serve my clients any better in the future and may cause me to leave the business.
Thank you for taking the time to read my comments.