August 3, 2010
Dear Commission Members: I have been a CEO of a FINRA Broker Dealer, and have various licences from a Series 7 to Series 28. I have held various offices within the FINRA organization, last serving as the Chair of the National Advisory Council.
I am an independant Registered Principal with Financial Network, thus I have no proprietary funds to sell, nor is my firm involved as Principal in trades of either equities or bonds.
However, it is my feeling that the rush to Fiduciary status for all reps is the wrong decision. If one were wanting to make the suitablity rule more conformed to todays standards of transparency, a simple disclosure to the client that the firm has both sides of the trade in its favor and that the rep insures that it is the cheapest and most suitable investment for the clients best interest, the standard is taken care of and transparent.
To go forth and impose stricter rules for suitability the words include would be for the "suitablity would be further defined as: always acting in the clients best interest.."
In my humble opinion, there are many other things to change, but reducing ways for our represtatives to do business is not the key issue to change in this current proposal by Congress. It will increase the cost to our customers and clients. I plea with you to find that the current rules for both Registered Advisors and Registered Representatives remain as they are today.
Craig A Jackson