August 2, 2010
To Whom This May Concern,
In my opinion, the move toward the fiduciary Standard, is a missguided attempt to 'protect' investors. In our industry today we are very tightly supervised and regulated using the Suitability Standard.
I hold essentially three licenses, Life, Health, and Securities series 6 and 63. I take these repsonsibilties afforded me very seriously. I have no intention of missguiding a trusting client into a less than suitable financial solution. The result of that action would cause me, my client, and my family great financial suffering.
I must maintain my Continuing Education credits every two years for my Life and Health license, and do an annual firm element training for my securities certification. This represents almost a full week in class or studies. In my office the cost of compliance each year is considerable. However, I also understand that we are being held responsible for a great deal of money and our clients financial well being. Therefore, many of the Suitability Standard measures are necessary. In my firm, we have very active oversight, and if they uncover any rotten apples, they don't last long at New York Life.
The notion that Fee-based only model is going to benefit the customer more, is just not so. Most of my clients would not be coming to see me if I was charging the usual $1000 fee to build a plan for them. Most fee based planners collect a fee and charge commissions. I don't think their advise is any better, because they charge prospects for their time.
This proposed action will result in Many people in this industry leaving it, and ultimately have very few financial professionals left to help the consumer. If Errors and Omissions costs become too great, I would be forced to find another line of work. This is what's happened in other countries, and it hasn't 'helped' the consumer, only hurt them.
It is my hope that you will NOT include the Fiduciary Standard in the bill moving forward. It's bad for the customer, and even worse for the industry.