July 30, 2010
Dear SEC,
I am an eighteen year veteran in the Insurance and Investment business and I am concerned about additional regulation of my business. I have witnessed a progression over my career of more and more regulatory reqirements and if I believed that my clients were any better off for them I would be all in favor. It is costly in both time and money and I believe that we are at a point where further regulation will only hurt our clients.
They will be hurt because there will likely be fewer of us that are willing to try and navigate the sea of regulation to provide good sound advice to our clients. They will be hurt because we are unable to discuss aspects of their investments like dividends and why xyz fund is better even though there is an upfront fee. We will overwhelm them with so much disclosure that they loose sight of what they were attracted to. Anything with that much legaleze can't be good.
I recently drove 70 miles to Rochester MN. to take my regulatory requirement for my series 6 and 63. As you know there are now four modules that have to be completed, one of those pertaining to anti-money laundering. I wouldn't have minded so much but I had just recently completed the AML training required by my Broker-Dealer. I work mainly with farmers and small business owners in rural Wisconsin. We don't see too many terrorists or organized crime folks trying to launder money here that it should be necessary for me to complete that training more than once in a year.
As President of Western Wisconsin NAIFA I can tell you that the advisors I encounter are good people that want the best for their clients. They take the time to further their educations and strengthen their skills to better serve their clients.
Please let us do what we do best. We simply can't deal with any more regulation.
Brett Welch, LUTCF