August 4, 2010
As a reg. rep., I'm already overburdened with paperwork and fees which I must pass on to my clients to cover my expenses and stay in business. Additional regulations and paperwork and fees will be not only onerous on me but also timeconsuming and costly for my clients as they must take time and pay the associated passed on fees. The proposed Frank Act would require that all broker-dealers be held to a legal and vaguely defined standard "to act in the best interest of the customer without regard to the financial or other interest of the broker, dealer, or investment adviser providing the advice." I already act in the best interest of my clients and don't need additional potential loomin threats of frivolous future lawsuits to be added to my business over the hindsighted definitions of "best interest". For example, is "best" the cheapest recommended product? The "best" premium relative to the benefit of the product? The product with the "best" historic underwriting and service standards? Is it the one from the carrier with the "best" rating? The fiduciary standard in essence adds a vague legal liability standard that looks back (sometimes after many years) and is enforced after the fact by the SEC or trial lawyers who have perfect vision in hindsight.
Please don't add any more burden and suffocating costly time-consuming regulations to my clients and me.