July 30, 2010
To Whom it May Concern,
As a Registered Representative, located in a small community, I feel I am over regulated as is. This new law will cost me more time and quite possibly put me out of business. This looks like the padlock approach. Padlocks keep honest people honest, and the crooks will find a way in no matter what your padlock or laws say.
I have done what's best for my clients for the last 22yrs. Those that have not have came and went and some went to jail.
I disagree that the fiduciary standard has protected consumers better. Basically, the fiduciary standard looks back and enforces breaches retroactively through SEC enforcement or private lawsuits. The suitability standard looks forward and tries to prevent harm to consumers through ongoing and frequent FINRA and broker-dealer audits and compliance processes.
The resulting regulation WILL have a very profound impact on howI serve my clients or even whether I will continue to do so.
I submit, I think there are enough unemployed now.
Stop the insanity, inforce what's already on the books, and let us continue to serve our clients.