July 30, 2010
I would like to comment on Fiduciary standards that are up for change. At Thrivent we practice a very stringent form of suitability questioning before we recommend an investment for our clients. I also take allot of time to educate my client and ask them what they expect of me and I also discuss what I expect of them if they are in a market sensitive investment. With the client fully informed and my "knowing my client" which is a standard already in place for registered reps in the FINRA guidelines I don't feel it is necessary to have legal fiduciary standards placed on me unless I have descretionary priveledges over the clients money. I can't move dollars or change investments like a fiduciary situation so I shouldn't have to be held to a legal standard of a fiduciary unless I have those priveledges with the clients dollars. This would create a legal nightmare where reps will be sued every time the market drops because the client will expect that we have the power to make the changes in their accounts when we don't have the ability. This is another case where there are plenty of laws and guidelines in place currently that haven't been enforced or have been ignored and creating another law that gives clients a reason to sue is just plain nonsense. Thank you for considering my comments.
Mark Carbaugh,