August 30, 2010
As an advisor that can serve clients in both the "fiduciary" standard as an IAR and also in the "suitability" standard as a registered representative I do not feel that the proposed rule holding all securities transactions to the "fiduciary" standard is in the best interests of my clients or my industry.
My fear is that the smaller clients that are typically served in the "suitability" arena will not be able to access advisors if that advisor is held to a higher standard of care than the current environment. If advisors feel that the compensation paid by these smaller clients does not justify the time spent on compliance and the risk to the advisor of litigation the advisor will simply not take them as clients. These people will then be recieving no advice or help with their financial affairs and I see that as a disservice to them.
Thank you for your consideration of my views.