Subject: File No. 4-606
From: Bryan Merillat

July 31, 2010

There is more than enough regulation within my profession right now. If I have a client who wishes to transfer/exchange a mutual fund, annuity or life insurance policy, there are several forms required essentially duplicating the same information.
The solution isn't more regulation--the "bad apples" will continue to simply ignore or by-pass the system. The additional regulations simply add time and cost to the b/d, the advisor, and ultimately the consumer. Why can't our legislative and oversight bodies recognize this simple fact??? The reality is there is no "fail-safe" solution to protect the consumer 100% of the time. Putting some former advisor/producers into the regulatory mix would help however, as they would have a better understanding of what "suitability" means versus an attorney who has no background in "the business".
To retard the rate of fraud/misappropriation of funds etc..., make the penalties more severe--longer mandatory sentences and capital punishment where warranted. When a so called "advisor" takes advantage of his client and damages that client's future and that client's family's future that "advisor" has forfeited his own right to his future.