August 24, 2010
Gentlemen and Gentle Ladies: I strongly oppose the SEC imposing another layer of regulation on Reg. Rep's, who already face very stringent oversight from their Broker-Dealers. We cannot see anything new in this Bill relating to oversight that is not already in place. The compliance rules and fiduciary responsibilities contained in the Dodd-Frank Act are vague, and without doubt are redundant.
Our industry is being dragged down with regulations. We don't need more of it. My question is what end purpose does this serve? Is there data supporting the need for this overlap, or acute levels of infractions? We believe that our "Suitability Standard" is easily sufficient. Over regulation by Government was the "Key Plank" in the Peter Grace Commission held nearly 30 years ago. Wise men fought this battle then, but few lessions were learned since. Be very careful what you give government-they never give back.
Jim Humphrey, LUTCF,CSA, Registered Representative (Age 66)