August 6, 2010
While it is clear that there is plenty of blame to be passed around for the financial meltdown that we all experienced as a result of the lax underwriting standards at the ratings agencies and GSA's (Fannie Freddie),proper caution and thought should go into coming up with a solution that can help to address these excesses.
Currently there is a very robust standard that governs broker-dealers and registered representatives. We spend alot of time making sure that we are in compliance, as well as putting the customers interest above our own. The bar has been set very high already and I don't see how my clients interests would be better served but putting on more layers of regulation. In fact the additional time and expense that is being proposed would only serve to add increase costs to the end consumer, as well as force me to spend less time with my clients, so that I can devote more time to complying with additional regulation. It seems to me that Independent Investment advisors should have a higher level of complaince required as they are potentially exposing their clients to riskier investment products.
Perhaps making the ratings agencies and the GSA have more skin in the game would serve to inhibit some of their outrageous behavior.
We are examined by compliance fairly frequently and it is ingrained upon us how diligent we must be in putting our clients interests above our own.
Please reconsider the potential ramifications, and unintended consequences of these new proposed layers of regulation.
Yours truly,
Abraham Fuchs