July 31, 2010
I am contacting you in response to the "The SEC has formally announced that it has begun a 30 day public comment period regarding its study examining the effectiveness of regulations governing broker-dealers and investment advisers" information I received from my government relations department at NAIFA.org. What I am concerned about with the SEC and the governmental definition of "fiduciary" responsibilities. To be brutally honest, registered investment advisors are under enormous compliance and regulatory rules with FINRA, compliance departments of each company and broker-dealer audits. They are regulated enough Furthermore, will having registered representatives be forced to become fee based planners really be the answer either? Who many families will this have an effect on? How are they going to pay these extra fees? What about our career agents in the industry? Will they have to be forced to become fee based planners as well? If so, this is going to drastically change for the negative for all captive advisors. If this happens, I foresee a gigantic amount of advisors leaving the business which will result in abandoning if not hundreds, but thousands of people (their clients) and their clients financial security. Our financial crisis will not recover, it will get worse. I think it would be wise to find a solution in discussions with our top NAIFA members who have been in the business and have made a tremendous amount of positive impact to their clients and communities. Do you really want to destroy that? Please do reconsider governing registered representatives. They are regulated enough