August 13, 2010
Expansion on SEC regulation to Broker/Dealer and Registered Representatives in unnecessary and costly to both the representatives and their clients. This will increase costs to both parties.
Compliance is already in place to protect clients from wrong doing or improper suitability from representatives. By adding more regulation, you will drive up cost, ultimately removing value to all transactions.
Error and Omissions insurance claims will increase dramatically, most without merit and cost brokers and agents more in settlements and in premiums. This cost will ultimately be passed on to clients through ongoing fees which wont benefit anyone involved.
I believe the SEC is looking past the largest problem. The problem lies in the market makers, institutional investors, hedge funds, etc. Joe and Jane America, who are making small contributions or making rollover type transactions are not causing the problem be cause a family investing $20,000 per year aren't a big enough player to effect the overall action of markets.
If you want to look at increased regulation, look to the institutions and hedge funds. Those entities that invest large sums of money at one time and causing the smaller investor to get caught up in their game and be negatively effected.
your proposed regulation will be negative for clients and force a large sum of regisered reps out of the business, therefore decreasing the amount of advise and service available to the general working public who are the people who need it.