August 6, 2010
Expanding the oversight of Registered Reps to include "fiduciary responsibilities" will greatly hinder my ability to meet client needs in the area of equities-based product selection. The largely judicially untested definition and implications of "fiduciary responsibilities" presents serious limitations to State Farm's sale of insurance products and the claims litigation possibilities that may result.
More significantly, the current regulatory and oversight process includes proactive (in advance of problems) scrutiny that offers better protection than "after the fact" litigation based upon the imposition of fiduciary responsiblity.
My relationship with and service to my clients will be negatively impacted by inclusion of "fiduciary" in the definition of my client obligations. Please do not move forward with this expanded definition.