July 30, 2010
Thank you for the opportunity to comment on the proposal to impose a fiduciary standard on broker/dealers. As you know, there is presently a suitability standard that takes into consideration the goals of a client when making transaction. It is a forward-looking rule that ajudges whether the transaction is in line with a client's objectives and his/her tolerance for risk. A fiduciary standard is essentially backward-looking in that it considers what happens to a selected security since the transaction date. My concern is that with such a standard, firms will need to raise costs and treat all of their clients as if they are in a fee-based relationship. This will be expensive not only for the firms but also the clients. And I cannot imagine how an internet trading platform will handle this, for example. So, my hope is that the SEC will weigh the costs of this standard on those clients who would prefer to have low costs with regards to their investment choices. The suitability standard does this effectively today.