July 30, 2010
I would like to make a few brief comments in regard to the fiduciary standard provision that you are considering on Registered Representatives. Right now we have so many regulations to follow, that at times it just over-whelms a person. I really feel that we have enough rules and regulations to follow. We don't need anymore. The compliance rules that both my company and I do is very adequate for working in the best interests of the buying public.
In order for me to maintain my license I have to have 24 hours of CE every 2 years, just for my life and health license. Plus, for FINRA, we have to "test out" for a 3 hour suitability exam. This two, is done every two years.
My point is with all this edcation and testing, why do we need more? We are already working for the best interest of my clients and the public. Every move we make is highly scrutinized. My company also has a yearly compliance meeting that all agents "must" attend, if we are to keep our license.
I just don't see how more regulation is going to help. If anything, it can drive up the cost to the consumer.
I'm not against doing what is right for the consumer. I feel we are already addressing the issues you are raising now. It appears to be over-kill, in my opinion.
I have been in the insurance business for 35 years and have seen a lot of good changes down through the years. Regulation of our indusrty has increasingly gotten tougher. In some cases it was needed. However, we are on the brink of getting ridiculous on over-regulating.
Please do not strap an unnessary fiduciary standard on an industry that already is regulated enough.
Thanks for listening.
Gene Beerbohm