August 3, 2010
Dear Commission Members:
I am an independant Registered Representative with LPL. I hold a Series 7 66. We have no proprietary funds to sell, nor is my firm involved as Principal in trades of either equities or bonds.
It is my feeling that the rush to Fiduciary status for all reps is the wrong decision. A simpler way to make the suitablity rule more conformed to today's standards of transparency is to provide a simple disclosure to the client. It should state that the firm has both sides of the trade in its favor and that the rep insures that it is the cheapest and most suitable investment for the clients. The standard practice of the always acting in the "Client's Best Interest" is fulfilled and transparent.
In my humble opinion, unnecessarily reducing ways for our represtatives to do business is not the key issue to address in this current proposal by Congress. I plea with you to find that the current rules for both Registered Advisors and Registered Representatives should remain as they are today.
Mark T. Dwight