July 30, 2010
Date: July 30, 2010
U.S. Security and Exchange Commission
R/E: File No. 4-6006
Study Regarding Obligations of Brokers, Dealers, and Investment Advisers
Dear Sir or Madam,
I am an Investment Adviser working under Allstate Financial. It is my option and from my perspective the suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard.
Compliance costs- both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.
I am a full time Allstate Agent licensed in Property and Casualty and Life and Investments. I hold both a fixed and variable appointment. I currently am 6 63 licensed. I am examined at least every six month by my firm by a supervisor whose primary responsibility is compliance and every three months by another leader who insures that I remain compliant in each area
It is my feeling that what is now required of our firm to insure compliance to the ever increasing number of regulations only adds to the cost of doing business and has minimal value to our customers. I am required to take continuing education classes, complete a Annual Compliance Questionnaire and I attend a Annual Compliance Meeting.
In my view regular reminders as to our responsibility to our customers is redundant and waste valuable time when we could be answering questions and helping them respond to the ever-changing landscape.
I take seriously my duty to help my customers make the appreciate decisions but to apply to us a fiduciary duty could mean that our cost of doing business will increase due to protection against a potential increased litigation liability. Additional expensive regulation is unnecessary.
My clients would not pay for up front fees and should that ever be the only way that we could help a client could mean that we would cease doing this type of business. I join with my NAIFA collogues who strongly oppose any addition restrictive rules to govern or destroy our business.
Mark R. Nelson
President, Nelson Insurance Agency