October 27, 2010
As a licensed insurance professional and financial advisor for more than 40 years I consider the proposed rule to put commission and fee levels in the hands of broker dealers to be very adverse to the best interests of consumers. I do not do much of this business at my age, but my long experience makes it clear to me that competition based on commissions - either up or down - is almost never in the best interests of the buyer.
In this case there will be a clear "race to the bottom" driving commissions and fees lower and lower. The result will be fewer practitioners, serving fewer and fewer middle income consumers who so desperately need professional advice and counsel, particularly in this time. Ironically the "race to the bottom" will create a "race to the top" as the remaining practitioners deal more and more exclusively with more affluent people.
I am all if favor of transparency, but society is best served in this case by maintaining regulated fees and commissions on security products. When consumers pay no commissions or fees in reality they will get what they pay for - nothing, at least nothing of real value to their retirement and financial security plans.
Please do not issue this rule.
Thank you.
David F. Woods, CLU, ChFC, LUTCF
Woods Financial Group