July 30, 2010
Comments attached- Having served in the insurance/financial services for the past 41 years, I have always placed the best interst of my clients first. While I at times have felt the oversight my broker dealer imposes on me has been onerous, I also recognize its purpose. I conduct my business in a professional manner, and while some contemporaries do not, I believe the vast majority do. As a Registered Representative I do provide quidance and qualified advice in many areas. In most cases that advice is given in the area of 401k and other qualified plan scenarios. I do not "manage" portfolios for my clients but instead provide them with the tools and advice to help them make decisions consistent with their objectives, risk tolerance and time horizon. I can tell you from experience, in particular within the 401k environment, the vast majority of consummers have no interest in becoming adequately informed and educated to put themselves in a position to make their own investment decisions including proper asset allocation along with rebalancing of portfolios periodically- each pf which are important components of a thoughtfully designed investment program. If I understand the intent of proposed regulations, I will have to function as a Registered Investment Advisor (RIA) if I am to continue to "help" the hundreds upon hundreds of plan participants, who to some degree, look to me on occasion for information. If I do not serve in that capacity these individuals will essentially have no resource as an RIA is not going to be bothered with a participant whose account balance is far below their requsite for the "fees" they charge for their advice. The point I am trying to make loud and clear is this: advice is not free. If the professional ultimately available to educate and help the masses is one in the same as an RIA, far more American's in modest 401k, IRA and other particpant directed accounts will find themselves without a "advisor" to turn to. I can attest to the fact the standard to which I hold myself along with the oversight of Nylife Securities, my broker dealer, assures my clients their best interest is always formost in my mind and my actions.
Terrence L. Wolf CLU/ChFC 302-658-0218