August 26, 2010
Being in this industry for over 13+ years both working in a Broker Dealer as well as out in the field as a wholesaler, I would argue that current suitability is already stringent, if not over kill and provides enough client fudiciary guidlines for registered representatives to follow and ensure proper investments for clients.
The new rule proposes a one size fits all box which we know is not the best and all clients do not fit in one box.
The Suitability standards currently governing broker-dealers and registered representatives are already stringent and heavily enforced. Current regulations already provide strong and appropriate consumer safeguards. Just go look at any Variable Annuity disclosure form at any Broker Dealer and you'll get an idea of how regulated registered representatives are.
We are already going to face an epedemic of advisors transitioning out of the busines in the coming years as there is a heavy degree of baby boomers currently planning to retire soon. Requiring compliance with 'fiduciary standards' will drive many advisers out of the market and eliminate a valuable advisory resource to consumers, especially in middle- and lower-income markets.
Driving every registered representative to fee-only compensation will not necessarily result in better, unbiased advice for the consumer. Not every client should be a fee only client and this model does not fit every person nor should it be required and pushed on all.
Please DO NOT approve this regulation.
Best,
Brian Crockett
RVP
Sun Life Financial