April 1, 2005
Regarding the new Point of Sale regulation. I have read over the proposal material and find the regulation to be onerous at best. Clientele already have a great deal of due diligence documentation provided to them plus remedies to address errors. E & O insurance is up over 350 in the past decade - CE requirements are up - Homeland Security paperwork continues to increase - BD oversight is way up - reporting procedures are double what they were just 5 years ago. Analytically it appears that we are targeting the lowest common denominator effect in the sales arena. Some clients are already balking at the latest paperwork effort from the BDs on background financial information prior to approval of a transaction. This proposal should be scrapped.