August 6, 2010
"comments attached"
In regards to a fiduciary standard being imposed
by the SEC, I know I am regulated to excess already.
This is not the time to increase the costs of doing
business when we are already required to go through
a series of check an balances. I have a 6 and 63
licience and I am audited 3 times per year to insure
I am doing business properly and professionally.All of
my transactions are reviewed by our compliance
department for all suitability issues.I believe
that is a positive and effective tool or process
in assuring my business is conducted in a proper
manner.Also, our current process includes up to
six different forms being completed and submitted to
our broker dealer and compliance department for
processing. Those forms currently take in excess
of one hour to complete and are detailed in the
the contact,advice, and recommendations I make to
a client.More control is not needed, but rather,
a system that insures all advisors continue to follow
the rules we currently have in place.The system
is not broken, there is no need to fix something
that is in good working order.