August 9, 2010
I am writing to express my concern over what I consider a misguided effort to impose fiduciary standards on Broker/Dealers(B/D's) and their invesstment advisors or RAPS. Your attempts to set these standards are duplicative and will do nothing to prevent abuses or breaches in appropriate behaviors or client advice. The approach you are proposing does nothing to address these behaviors in advance. Your approach is purely retroactive. The currently in place suitability standards and training we receive through our BD's is a proactive approach and has many checks and balances.
Compliance is already cumbersome enough for the average representative in this business without adding another layer of compliance measures that aren't even proven to generate the desired results. If this escalation of compliance continues, pretty soon there will be no one for the public to turn to for any constructive information.
They will have all been driven out of the business. I'm sure that the public would agree it's already a much too difficult investment world to be navigating without the benefit of a trusted advisor.
Sil L. Arata