February 6, 2005
What is the benefit of adding an additional registration requirement to my current burden of the B/D? As a CLU, ChFC, CFP I have requirements to serve my clients appropriately. The NASD suitability regulations allow them to insure the client is properly served no matter how the service is priced. The RIA regulation has been less stringent than what has been required of small B/Ds like mine. To add additional registration requirements would allow less time to serve the needs of my clients add more costs and hinder my ability to give them the care they should have.
If you put the RIA regulation under the NASD then evaluate what is necessary if that doesnt fit what you desire. There is no client benefit on setting how a client is charged for services. Is a one time commission for the purchase of a US Treasury better than an ongoing asset based fee? Is a Fund F share for RIAs better than the A share for a larger client when the ongoing expense of the F share is greater? Isnt suitability the issue?
What does this issue gain for the client? My designations require me to have additional responsibilities but I think this is good for the client, not whether I am affiliated with a B/D or an RIA. How the service is paid for should not be the reason to add regulatory burden.
The product providers are part of the problem you are missing in the overall picture. Banks, Insurance Companies and other financial assets need to be included in the picture to better serve the public. This proposal does not seem to add protection to the client even if B/Ds become RIAs.
Thank you for the opportunity to submit comment.