August 2, 2010
To: SEC
I've been licensed for Life Health Ins. since Jan. 1963 and Securities Business since 1990. I've always believed in asking my client what it is they want to accomplish and then explaining how my product will fill their objective. Not only do I explain how the product will fill their need but I always explain disclose everything about the product they are buying,.....in other words FULL COMPLIANCE DISCLOSURE. I have great persistancy of my business (it stays on the books because the client knows what they have) and have NEVER HAD A ERRORS OMMISSIONS CLAIM on life, health or securities products I've sold. Since I've been in this business I've seen REGULATION COMPLIANCE increase tenfold and yes some of it was needed. However, I think we are to the point where we are over regulated and now spend an unduly amount of time in complying with consumer regulations etc. Evertime there is a guy like Bernie Madoff who screws the consummer, Washington shouts, "there needs to be more regulation". Washington and it's hoard of securities regulators can't or don't enforce the regulations we have now. The Bernie Madoff case should have never happened had the SEC, FINRA who ever else is in charge of securites, been doing their job. You know it I know it to be so.
I hold a Series 6 Securities License as well as a license for Life, Health Annuites. When I submit a piece of Secuities Business there is enough compliance paper work to choke a horse,..literally. How much more regulation do you need? The SUITABILITY STANDARD we currently use is serving the consumer well don't feel the FIDUCIARY STANDARD will do any better but add more litigation and added cost to the Rep. Consumer. Let's inforce the regulations we have and forget about adding more burdensome regulations which are NOT NECESSARY in my opinion.
Sincerely,
Henry E. Lehn,CLU,ChFC
Lehn Financial Services, Inc.