August 2, 2010
As a Financial Advisor, Licensed through my Broker-Dealer to perform Fee-Based Comprehensive Financial Planning Services. As such, I abide by very strict Compliance and Regulation, which already take great time and expense. A minimum of 10% of my time spent on any client case is expended on Compliance Reporting via Forms, E-Mails, and FAX, plus COmputer Test/Tutorials required each year for FINRA Registration, plus my own Company's Compliance Requirements, to satisfy FINRA. Time equals Money in every business, and if the SEC imposes any additional regulation such as the proposed Fiduciary Standard on Registered Representatives, it will simply take more time away from the finite amount of time I have to serve my clients. That, in turn, will cause me to charge higher fees to my clients in order to keep my doors open as a viable professional practice.
I am Licensed with the NJ State Dept. of Banking and Insurance, for which I must continually obtain COntinuing Education Credits, and submit proof of good standing, as far as maintaining a clean record across all areas of personal and professional conduct, in order to renew my Licenses.
My personal assistant and I spend 20% of our time keeping records of my Compliance and Licensure across all areas of my Practice, from Life Health Insurance, to Property Casualty Insurance, FINRA Securities Products, Banking Products, etc..., across 20 States where I am licensed.
My Staff and I should spend closer to 100% of our time Advising and Serving our Clients, NOT engaging in ever-increasing Compliance and Regulatory exercises which ultimately hurt our clientele by taking our focus away from their specific concerns, goals, and objectives, which requires our exceedingly close attention.
I implore the SEC to NOT impose any new, misguided, Fiduciary Standard on me and other Advisers.