Subject: File No. 4-606
From: John R Bicket
Affiliation: Registered Representative

July 30, 2010

Ive been a financial professional for thirty-five years and counting.

I disagree that fiduciary standards have protected clients– increasing the fiduciary standards and regulations will only create more money/time wasted on an already broken compliance practices.

I have hundreds of clients and hold licenses in four states. Each state has its own set of CE classes that must be taken however, the how and where these classes must be taken is already confusing. Each broker dealer has a certain company they go through to complete the CE classes and the methods of taking the classes are always different.

Im examined every time I submit business, which usually adds two to three days on the processing time of an application. I have on staff someone whose main job is to make sure all compliance is met on each and every application. Although this person focuses on all the little nuances of compliance, its still difficult for us to keep track of what needs to be submitted. The compliance and applications seem to change every few months making it difficult for everyone in the process the sponsor company, broker/dealer, employees, and client, to be on the same page. Its understandable that frequent changes in regulations and forms make it difficult coordinate a smooth writing process and I hope SEC recognizes this too.
Aside from all the extra time and money spent contacting multiple companies to make sure we have the correct form every time we write business, the relationship between the agent and client hurt too. The excess paperwork, the wait times, and changing forms, all add to discourage clients from utilizing a financial professional for their needs.

Even after the business is submitted, Im still expected to keep track of every time I correspond with a client. I have to keep detailed ledgers and copies of that correspondence through the year.

These are just a few of the problems surrounding the over regulated and over scrutinized compliance process.