August 4, 2010
The current suitability standard is robust and heavily enforced by our broker/dealer.
- I hold series 7 and 63 licenses, and am required to submit thorough suitability information on clients. This is carefully reviewed by our broker/dealer and subjected to inquiries whenever there is the slightest question about the appropriateness of an investment vehicle.
- Our office is subjected to SEC compliance reviews at least once a year.
- As a member of the B/D' s corporate RIA, my files are subjectedt to on-site scrutiny at any time.
- Compliance requirements involve a great deal of detailed paperwork on client suitability issues whenever any investment application is submitted. Paperwork is carefully screened by me, my assistant, our in-house compliance officer and by the broker/dealer. A great deal of time is added to my work for this purpose.
Imposing a fiduciary standard could result in the following problems:
- Having to move to a fee-only practice.
- Losing clients who cannot afford fees.
- Increased EO insurance premiums
- Possibly discontinuing the investment side of my practice and concentrating on insurance planning only