August 3, 2010
As a registered representative with a 6 and 63 and also holding a life and annuity license, I am already subject to several layers of compliance. I have a required annual compliance meeting held by my broker/dealer, my e-mails are monitored and all my applications are reviewed by my compliance department for suitability prior to being acted upon, which can cause a delay for the client. Additionally, every three years I am required to pass a firm element exam to ensure I understand how to act ethically in dealing with a client. From the insurance side, I have continuing education credits including ethics courses. A newly instituted annuity course is required.
In completing an application, I have more forms regarding compliance than the product application. Many clients comment that there is as much paperwork to open an account as there is to purchase a home Much of it is duplication. More compliance will make the process even more cumbersome.
Most people are reluctant to seek financial advice for fear of what it will cost them. If I am forced to go to a fee only model, fewer middle income people who need advise the most will be able or willing to pay for it with a large up-front fee. Our society has a great need for these people to save more and seek advice-please don't make it more difficult by adding more costs.
I already have a fiduciary duty to my clients by being a CLU (Chartered Life Underwriter). Perhaps consideration should be given to recognizing accredited designations which entail education of the advisor. Requiring more compliance puts an unnecessary burden of expense and paperwork where there is already ample of both. To protect myself from future lawsuits, I will be forced to make changes to my business model resulting in higher expenses or take an early retirement. With the aging of America, I feel my skills are needed but I cannot continue to spend more time on compliance paperwork than I do with my client.
I implore you to not add another layer of regulation.