August 6, 2010
I appose adding more regulation between a financial advisor and the public. The public does not understand the layers and layers of regulation currently in place. Adding more, will just confuse the public more and make misrepresentation easier for unethical reps.
I currently spend 1/3 of my time in compliance activies. I am audited by my Broker/Dealer at least 4 times a year, which typically takes days to prepare and a full day on the visit. Current compliance looks forward in time to prevent abuses, after reviewing looking back. Your new regulations consider looking back to punish what may have already happened (which already exists with the SEC) We need focus on prevention, not just looking in the rear view mirror.