October 28, 2010
As a registered Financial Representative in the state of Illinois for the past year I have many concerns surrounding the Proposal above. This action would open up the flood gates of irresponsible practice by broker dealers and our middle income investors would suffer this through heightened financial risk. The parts of the proposal speaking to transparency for the investor in relation to these fees is valid, but to offer individual b/d's the opportunity to set their own fee scales is ludicrous. Through price slashing in an effort to gain market share and build business, b/d's would be able to lure investors to bring assets to a company without providing the requisite and currently enjoyed obligation of the Financial Representative to actively offer individualized advice.
The danger in this is that those who are savvy, see the need and can afford to pay the current and reasonable fees for representatives eager and willing to provide the services the fees provide for will have an inherent market advantage over those who have chosen a b/d as a result of having their cost needs preyed upon.
It is worth noting as well that this leaves a large door open for malicious practice. Preferred clients can invest with a b/d with a reduced fee structure and still be given advisory and management services that others pay higher fees to receive.
Please consider voting this proposal down and partner with the industry in an effort to revise it to a sensible and client-benefit based solution. Say no to alienating middle market investors with lack of professional service. Say no to reducing the ability of a registered financial professionals to make a competitive living providing the investment advice and services essential to maintaining financial security for their clients. Say no putting America's investors at long term financial risk under the guise of providing a more competitive industry.
Many thanks and kind regards,
Patrick N. Williams