Nov. 02, 2022
November 2, 2022 The more proposals that come out the more I fear the current commission is doing the bidding of the mega brokerage / ria / aggregator firms. Commissioner Pierce's comments were spot on across the board. As a compliance officer at a small/medium RIA in my early 30s, the continual and on going onslaught of rule making is demoralizing. The commission seriously discounts the amount of human capital involved in complying with the never ending string of new rules. The commission staff get to work on exciting cases to catch bad actors (more often just harass small to medium firms on technicalities with no client harm). They have guarantees of fat pensions on the tax payers dime, and seldom leave unless for an even higher pay out from a big private firm. Further, they have virtually no risk of ever being fired or having serious consequences for something missed in their work. On the other hand, compliance officers actually have to pour hours of their lives on a recurring basis into Sisyphea n efforts that make no difference to customer protection. Compliance should be first and foremost about protecting clients of the firm and ensuring that their financial goals are achieved. This rule adds nothing but benefits mega / aggregator RIAs and third party vendor management servicers. It will further misallocate capital in search of a problem which does not exist.