August 2, 2010
I will try to state my comments in a simple format.
1. Do not add any new regulations to Register Representatives. We are already regulated enough.
2. Adding a Fiduciary duty to all Reps and Broker dealers will only complicate our paperwork, time, and compliance. The suitability standards that we have are enough.
3. In the 'best interest' of the client is too vague. We all try to work in the best interest of the client, but that can be analyzed in a number of ways. Possibly causing a ridiculous number of lawsuits. Each client needs need to be considered individually: product fit is not the same for each person, age, health, fees many factors need to be considered.
4. The cost of staying in business is already too high, required minimums are too high. Errors and omissions insurance is too expensive. To stay in business all reps need to have high net worth clients with a lot of money to help them with. Not all Reps have high net worth clients. I personally have a lot of average or even below average net worth clients, who can't afford to put much away every month, and couldn't afford me if I were to be fee based. Who will serve these clients if the new regulations put me out of business?
Please don't over-regulate, causing cost for everyone to go up. It will definately hurt the 'little guy' if you do.