July 30, 2010
File number 4-606 does not due justice for providing a greater standard of protection for individuals than the suitability requirements already provided. The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. Compare and contrast it to how you see the fiduciary standard governing investment advisers is applied and enforced.
It will add another layer of time and costs passed onto an already time intensive process for clients.
I currently hold a 6 and 65 license and will be pursuing a 65, which is no easy task. I currently do all the required paperwork on my own which does not allow me to see the people I want to see. I am looking to hire someone to help handle the already time and money intensive process.
The new additional compliance requirements will only make it more difficult to complete business to an already compliant regulated process.
The current compliant regulations makes it difficult for anyone to get into this business. My fear of this new layer of regulatory compliance will provide greater hinderance to an already regulatory intensive field. Please reconsider the new fiduciary regulation to an already highly regulated suitability requirements needed to assess when completing business with clients or potential clients.