August 7, 2010
Thank you for the opportunity to comment. I would like to echo the voices of most other practitioners, who have commented here, and say that the idea of protecting the interests and acting in the best interest of consumers/investors is very admirable.
That being said, it is my opinion that legislating or regulating to that end is a flawed means. The trend in the industry is already going in this direction - many brokers are embracing the advisory and hybrid advisory/bd models. I am in favor of letting the competetive market among professionals ultimately guide them in the direction of a "fiduciary" standard.
Adding to the already heavily regulated environment of licensed financial professionals will serve only to marginalize the most vulnerable investors and make an already bad chrisis a whole lot worse. Everyone knows there is a retirement savings chrisis in America. Most "average" Americans do not have a chance when it comes to having enough to retire on. If I and my colleagues are faced with higher expense, masked in the form of bureaucracy, in one way or another this will get passed on to the consumer/investor. Only those consumers/investors who can afford it will get the guidance of a professional, leaving the "average" folks without guidance and thus, by proxy, harmed by their own government.
I respectfully request the Study to consider this aspect when put in the perspective of the citizens who will be most affected by it's outcome.