July 30, 2010
I am writing to comment on the possibility of imposing a legal fiduciary standard on broker-dealers and registered representatives. I am a registered rep will Allstate Financial Services. I believe the proposed action would have a huge negative affect on both my business and my customers.
I am currently highly regulated. EVERY account I submit to my broker-dealer is looked over by suitability specialists. I am audited at least twice/year. I am required to document continuing education and yearly training in suitability issues. I don't feel imposing this standard on myself and thousands of other hard-working small business owners will result in better outcomes for our customers. In fact, just the opposite will likely occur.
Our options will be to begin to charge customers extra fees or get out of the business altogether. Since most of the representatives affected by this new rule serve mainly middle to lower income customers, it would have a great affect on the availability of these customers to find good financial advice.
I urge you not to place another layer of regulation on an already highly regulated business. Allow us to continue to serve our customers as they deserve.