August 2, 2010
I've been a registered representative having held a series 6 and 63 securities license since 1984. My broker-dealer requires that I devote several hours each year to regulatory and compliance trainiing. In addition, I have devoted substantial time and money to obtaining professional designations to gain the knowledge and competence needed to do the best possible job for my clients. As a matter of personal integrity, it has always been my practice to recommend only those insurance and financial products that are deemed suitable and in the best interest of my clients based on a thorough review of their financial goals and needs. In my 26 year career I've only had one complaint which was quickly and fairly resolved.
For me to have to register as an investment investment advisor and possibly convert to a fee-baed practice for fiduciary liability reasons will only add another layer of regulation and compliance which will not add any additional consumer protection but will mean added expense and time for me and my broker-dealer which will eventually find it's way to the consumer.
The Dodd-Frank act while it may be well-intentioned is misguided and counter-productive to the goal of better consumer protection. I'm sure there some institutions or indivisuals lobbying for this legislation that will benefit from it, but it will only be damaging to the majority of representatives like myself and the clientele we serve. Perhaps a better option is to enforce existing regulations before making the regulatory situation more complicated and costly.