August 12, 2010
My Comments regarding File No. 4-606 Study Regarding Obligations of Brokers, Dealers, and Investment are as follows:
- Advisers Suitability standards currently governing broker-dealers and registered representatives are already stringent and heavily enforced. Current regulations already provide strong and appropriate consumer safeguards.
- Requiring compliance with 'fiduciary standards' will drive many advisers out of the market and eliminate a valuable advisory resource to consumers, especially in middle- and lower-income markets.
- Additional risk of lawsuits involving registered representatives will increase costs to consumers.
- Driving every registered representative to fee-only compensation will not necessarily result in better, unbiased advice for the consumer.
Thank you for your consideration of my comments.