August 30, 2010
With regard to the broker-dealer/reg. rep. issue we are regulated enough. Compliance costs- both in terms of finances and time-are high, and these costs are eventually felt by clients. Adding this regulation means more compliance and costs. The licenses that reg. reps. hold, whether insurance or securities, already requires considerable continuing education so that reg. reps are able to maintain the professionalism to assist clients properly. Additionally the paper work involved with compliance is already enormous and will become greater thus impacting our ability to service our clients properly. A large part of our administrative assistants time is already spent on compliance issues. Passage of this regulation would not only increase cost such as EO coverage and clients fees but will cause some reg. reps. to abandon their reg. rep. role and work soley on a fee based level.This in turn will provide less professional reprs. to assist clients and more clients will be on their own.