August 31, 2010
My comments regarding fiduciary standards vs. suitability standards are based on my 39 years of experience in the financial services industry. I started in this business when I was 23 years old. I am now 62. During this almost four-decade career I have never had the occasion to answer for any complaints from my insurance and investment clients, all established clients by the suitability standard.
Many of my financial planning clients are of middle-income with a substantial number of them middle- to low-income. I typically do not charge fees when I see it is a hardship on borderline budgeted clients. I often provide my advice free of charge and look to insurance and IRA investment needs as the only potential compensation. Sometimes this works well, other times I have invested anywhere from two to five hours for free.
Should the financial planner relationship become a required fiduciary relationship, I will no longer be able to provide my financial advice at minimum fees or no fee at all. Not one client in 39 years has complained that my interest was placed above their best financial interest. I have taken great pains to establish suitability for all my clients regardless of income and circumstance. I will not bear the financial and compliance cost that will be passed on to clients who cannot afford to bear such cost. This low-end market will be lost. I cannot afford the liability or the time to meet the fiduciary standard unless my clients and I have agreed to such a relationship ahead of time with the understanding that an additional fee must be charged.
Where is the $40,000 per year wage earner going to go for financial planning on a fiduciary standard fee basis? The $53,000 wage earner? The middle income wage earner of this country has every bit the need for financial planning that someone earning two or three times that amount has. Of course, there is little to no discretionary income to pay for financial planning fees which must be charged due to the increased liability and time required to meet the fiduciary standard.
PLEASE--my clients and I do not need another layer of bureaucracy and regulation increasing the cost of financial planning. Its time consuming enough to establish suitability and complete all the compliance requirements necessary in order to stay compliant. Again, please, no more compliance requirements increasing liability and administrative costs to my client and me
Steve Summerlin, President
Summerlin Financial Advisors, Inc.