August 24, 2010
The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. Compare and contrast it to how you see the fiduciary standard governing investment advisers is applied and enforced.
Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.
My primary concern is that these chage will make it more difficult to serve middle America. As costs go up average size of sale needs to go up to stay in business. This means less of America will be served.