August 24, 2010
I want to emphasize to you that I believe the suitability standard governing broker-dealers and registered representatives is alive and well--it is heavily enforced and certainly does not need to be augmented and burdened with an additional fiduciary standard as proposed. In the past 5 to 10 years major time commitment has become necessary for a representative to monitor their compliance and that time cost not only the representative but adds to the cost of products and services provided to the clients.
I am a registered representative and hold life and health and property and casualty insurance licenses. For each license I am compelled to take continuing education-6 to 8 intense courses-at least every two years. In the case of the registered representative continuing education, every year we are required to do several courses to keep us updated as well as courses on ethics.
If the proposed fiduciary standards are imposed, many of us will be going to fee services which will cut out many clients that need our help but are not able to pay up front fees.
Please do not impose the fiduciary burden to our already burgeoning compliance requirements and take service to clients to a lower level. Thank you.