July 31, 2010
I am a registered representative. I work in both the insurance and investment fields helping my clients reach their future financial goals. I feel it is very important for the SEC to look closely at this study and determine what is best for clients and consumers. I currently act under a suitability standard and deal with many different regulations and compliance issues in doing so. In our local firm, there are at least 4 people watching compliance issues at any given time. This does not include myself and my staff who regularly spend time reviewing compliance issues, updates and changes. We take this very seriously and we always put clients first. The current system allows us to do good work for our clients without excessive fees and costs.
Moving to the fiduciary standard would change the game. The liability of this backward looking regulation would increase the cost of doing business. Regardless of how diligent we are in serving our clients, there will always be a risk of legal action based on how things turn out. I truly believe this cost of doing business increase would eliminate many clients from having any servcie at all. Many of my clients are young families without the capacity to pay a fee for my services. The current regulatory environment and commission structure of insurance and investment products allows me to provide great help and education to them without making the service unaffordable. I believe a change requiring all in my industry to be held to the fiduciary standard would leave many clients on their own without services.
I urge you to maintian the current two standard system. This provides chioces and options on all sides. Those who wish to have a fiduciary relationship have that avaiable. They can handle the costs and feel comfortable with the services they receive. Those who cannot afford or will not pay for this increased requirement have the option of determining a relationship that will fit their needs. Allow the marketplace to work and those who do not look out for their clients will be weeded out.