August 30, 2010
Dear Sir or Madam:
I am writing in response to request for comment regarding the SEC Study under the Financial Services Regulatory Reform.
First, I have been a licensed member of the insurance industry and financial services for nearing 33 years and hold numerous licenses, registrations and designations. It was essential from day one to earn and maintain trust of my clients by, first, being an honest and ethical individual. I soon undertook the rigorous study to earn the CLU (Chartered Life Underwriter) where part of the pledge references that the work and recommendations that I do for others would be no different than if I were doing it for myself. I live that without thinking about it and a 33 year career only continues because my clients trust my work and refer others to me as well.
I have also said I will still help a client save their first $25 dollars. And, for that first savings of $25 per month it literally takes years to recoup even the costs and overhead expense to initiate the habit forming change that individuals must do to prepare for their life ahead and be responsible for their own destiny. These people could never pay me a fee that would cover those same costs. Rather, my costs are recouped over years of earning from a few cents to a few dollars, and a continued growing relationship with those clients that yields referrals to family and friends.
In the early days of my career, I took both morning and afternoon coffee breaks and the lights in the office were out at 5PM. Now, it seems like I am less able to be available for my clients while spending many weeks per year in training, compliance, oversight, regular and repetitive documentation, office visits, file review, documentation, staff time in record keeping and paperwork, duplication in licensing and fees at the state and federal level, insurance licenses in multiple states and sometimes by the county, all to the lessening of availability of me to my clients. Being from a small rural state, like health care, first, access to a physician for the services needed in the communities that people live is a first priority. No amount of regulation, attention to rules, penalties wages, or cost/benefits measured matters if there is no physician with the knowledge and credentials to deliver the service needed. In our profession alike, the average age is in the mid 50's and soon a critical shortage of availability and access to professionals with knowledge and ethics to be trusted will disappear. I would like to someday turn over my clients to highly qualified, younger associates, who will be there to serve the needs of my clients, their children, grandchildren and great grandchildren for I have some families that have entrusted four generations to me. Further, the profession has become so cumbersome that it is very difficult and the recruitment and retention of newer, younger associates to one day provide for that orderly transition, I fear will leave my clients underserved, or unserved.
I see this opportunity for the SEC study to truly review and remove redundancies while maintaining high quality requirements to protect the consuming public and still provide for availability and access to highly trained and qualified people to serve their fellow man, neighbor, friend, family member and their communities in which they live and work. Service to middle America is what I do. I help them cover risks and save money. I believe in appropriate regulation, but not so much to create unintended consequences.
I thank you for the opportunity to make comment regarding the SEC study.
Elaine J. Fremling, CLU