July 30, 2010
Broker-dealers and RIAs are currently regulated by both the several States and FINRA(formerly NASD). Any further regulation would unnecessarily drive up the costs of doing business for any RIA or broker-dealer.
In addition, requiring FEE-only commissions would set a financial professional AGAINST the best interests of the consumer, since a professional would then want to generate revenue.
Furthermore, the SEC regulates securities, exchanges, and companies -- NOT financial professionals. Federal law notwithstanding, I believe that it is improper for the SEC to undertake such regulation.
If proper, such regulation should be by FINRA and the several states.
Therefore, I urge you to NOT impose any additional regulations on RIAs or broker-dealers.