August 2, 2010
I would like to EMPHATICALLY state my opposition to any initiatives to add further bureaucracy and EXPENSE to the process of helping clients make APPROPRIATE decisions regarding investment products. There is already a VERY EFFECTIVE set of "checks and balances" in effect, requiring proper due diligence in making recommendations to clients or prospective clients. The current standards due a fine job of protecting these "prospects" IN ADVANCE - as a pro-active stance. Adding another layer of retroactive bureaucracy by imposing the fiduciary standard is both unnecessary and COSTLY, and brings no more "value-added" to the client.
I hope a Series 7 (General Securities) license - and have for 37 years. I take my responsibilities to my clients very seriously and (as do, I believe, the vast majority of my colleagues that hold meaningful professional designations, as I do) spend a considerable amount of time every week studying, researching, and meeting my required compliance mandates. I am audited at least once each year.
Moving to a fee-based "model" would absolutely NOT change my "modus operandus" and certainly not result in "more unbiased" advice.
THE SYSTEM IS NOT BROKEN...........therefore, it does not need to be "fixed" by complicating the mix with further requirements that take away time and inevitably result in additional costs that trickle down to THE CLIENT. The end result: a less efficient, unfair burden to those of us entrusted with the best interests of our clients.