August 26, 2010
I would like to express my opinion about the fiduciary standard you are proposing. I am opposed to this proposal and have summarized a few points below. I have many more thoughts however, at this time, I do not have the time to elaborate.
1. 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.
2. 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.
Your consideration of this matter is greatly appreciated.