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NAIFA Comment Letter to SEC on Duties of Brokers, Dealers and Investment Advisers (PDF)
National Association of Insurance and Financial Advisors [NAIFA] Link to more items from this source
[Opinion]
July 3, 2013

19 pages. Excerpt: "As both licensed insurance producers and broker-dealer registered representatives, [National Association of Insurance and Financial Advisors (NAIFA)] members are currently subject to a comprehensive regulatory regime consisting of state insurance laws, state and federal securities laws, self-regulatory organization rules and the compliance policies and procedures of their broker-dealers... As a result of these multiple regulatory layers, NAIFA members are among the most comprehensively regulated individuals in the financial services industry.... The imposition of a uniform fiduciary standard could result in registered representatives having to significantly increase the time and resour ces they devote to regulatory compliance, which would, in turn, lead to increased costs for the registered representatives and increased prices for their clients. The likely result would be a decrease in services and advice for less well-off clients, who are less able to afford higher prices for service and assistance."

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