June 8, 2013
I write in opposition to the proposed fiduciary rule. Here's my deal:
1. In 1982 I won a bid for a 403b block of business from a school district. Ultimately, the block of business grew to near 3000 people and 50,000,000 dollars.
2. Teachers are fairly conservative. They want conservative (eg fixed income products).
3. Circa 1987 I introduced a variable product that enabled people to move into funds at no immediate cost to them
4. Circa 1995 I introduced RIA services for those of my clients who wished. To those clients I acknowledge a fiduciary responsibility. But for the others, I submit, it constitutes a force they do not wish to be involved with.
There is a place for both forms of practice.
Finally, there is no proxy on ethics. I have seen hugely immoral acts by both sides in the controversy in my history.
Question: If the heart of the issue lies in self custody of RIA assets, my point to you would be to simply mandate 3rd party custody of assets.
Thank you for hearing me. Chuck
Charles K. Arnold