August 25, 2010
I am writing to you requesting that you abandon the idea of imposing "Fiduciary" responsibilities on registered representatives. I have been selling group as well as individual life and disability insurance for 29 years. In addition, I have been selling series 6 related products for 25 years. I have never had a complaint registered against me. I have taken great pride in trying to match appropriate products to my client needs. In fact, I have left 2 companies over my career because I refused to sell products that they deemed corporately profitable but that I did not see how they met my clients' needs.
In America today, we are already under too much governmental supervision. FINRA, my Broker-Dealer and the Mississippi Secretary of State already do a substantial job of regulating my sales and marketing efforts. I just returned from the Czech Republic on a church mission trip. Because of the years of Soviet domination and intervention in their lives, the people there are suspicious, fearful and less trusting than we are in America. More government regulation creates a sense of oppression rather than a spirit of entrepreneurism. I am all for protecting the public from scam or deceitful marketing practices. However, imposing more Federal regulation at the lowest level, that is on the agent/rep in the field, will cause such undue and unnecessary expense, suspicion and potential for aggrandized liability suits, that you will likely create more harm than good.
Let's promote ethical business standards rather than "fear mongering" brought about by Federal regulation. Let's celebrate people making good personal financial decisions such as investing in a mutual fund on a regular basis to create personal and family wealth rather than presuming that since I make a commission on a mutual fund sale I must be acting in a way that is not in the best interest of my client.
If Mr. Frank and Mr. Dodd want to impose regulatory oversight on businesses, how about the unbelievable rates of interest credit card companies are allowed to charge? 29.9% interest is what God refers to in the Bible as "usury." Now there is no way that can be considered in the "best interest" of the consumer. Some day God will have his way with America for trading freedom and self-regulation for the view that the Federal government can and should provide everything for all citizens. Some day he will deal with the banking industry for having charged such unbelievable rates of interest and he will also deal with those who created the laws that allowed them to do so.
The vast majority of my clients are low to medium income people. I view it as a privilege and an honor that they would trust me to provide them with a life insurance policy and a mutual fund for a total outlay of $150 to $250 per month. I am thrilled to help them protect their families and create family assets at the same time. However, if I am to come under additional Federal regulation and thus have to pay more for EO coverage and be responsible for even more regulatory paperwork, I will not be able to service those who need me the most. I would hate to have to tell someone "I'm sorry, I can not afford to help you because the Federal government imposes such oppressive regulations upon me that it costs me more money to work with you than I will make."
Let me be very clear. MORE Federal regulation, supervision and provision in our lives is NOT what we need especially at the base level where an agent provides a direct service or product to the client.
Thank you for your kind attention. I hope that you act with great caution prior to exercising even more Federal regulation on me, my professional peers and our respective clients.
Ronald D Kyzar