April 7, 2014
As an independent financial advisor, I support regulatory efforts aimed to protect investors. I agree with FINRA`s goal to disclose material conflicts of interest to investors, I am in complete agreement with FINRA`s proposed rule on recruitment compensation disclosure. I think "it`s about time!" I have seen, first hand, how so many brokers jump from one firm to the next, receiving bonuses each time they do it. And just who pays for this? The clients get stuck with the closing & transfer costs every time!
The proposed rule should be required at $50,000. Any amount greater than the actual costs borne by the advisor to physically move, change signage, letterheads, etc., should be an event that is required to be disclosed.
While I believe that "Recruitment Compensation Does Not Automatically Create a Conflict," it needs to be disclosed to protect investors.
The Disclosure Does Not Violate My Privacy: As an independent financial advisor, my clients live and work in the same community as me and I often maintain both a personal and professional relationship with them. FINRA`s rule should force me to disclose extraordinary payouts, such as these, in the interest of full disclosure.
For these reasons, I believe the rule proposal is long overdue and a responsibility that many advisors have previously ignored.
Thank you for considering my comments.
Mr. Robert Studniarz