August 2, 2010
The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. Compare and contrast it to how you see the fiduciary standard governing investment advisers is applied and enforced.
#61607 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.
o Discuss the specific licenses you hold and what is involved in complying with each license.....Life, Health and Securities (OSJ, passed 24 and 65)
o How frequently are you examined? At least once a year
o Give specific examples of how much time you (or someone in your office) spend on compliance. How much paperwork is involved? Have you had to hire someone into your office whose sole job is keeping up with compliance? Daily 20 minutes to an hour of redundant paperwork
o Are there areas of compliance that do not add any consumer protection in your view? VA's have become rediculous between the securities suitability reviews and the insurance compliance. How do the compliance requirements impact your ability to serve your clients?
Yes, inordinate amount of lost time spent on pokey forms that don't stop any bad guys because they know how to manipulate, just slows down the good guys and makes us think twice before recommending plans that may be in our client's best interest.