Stavis Wealth Transfer Solutions Comment On Regulatory Notice 25-05
Deborah Stavis
Stavis Wealth Transfer Solutions
Dear Ms. Mitchell,
I am the owner of a Registered Investment Advisory firm in Houston, Texas, with five employees and a registered representative of an unaffiliated FINRA member firm.
My position is that rule 3290 in regulatory notice 25–05 would duplicate oversight, and the inefficiency is likely to create unnecessary complexity for RAA’s, unaffiliated Broker Dealers, and most importantly, valued clients.
Client confidentiality is the cornerstone of our business, and their information is protected under federal law, specifically Regulation Capital S P. State privacy laws also protect the confidential information of investment advisory clients.
I have read the proposed rule 3290, and it would appear that there are myriad of conflicting rules and confusion. This is likely to confuse clients and advisors alike, making it difficult for our business to operate and for clients to have clarity and confidence.
As Fiduciaries, we are already subject to the highest standard of conduct. The imposition of overlapping yet unclear FINRA rules creates a burdensome, duplicative regulatory environment and serves no purpose other than expanding FINRA’s jurisdiction.
Also, the proposed rule claims jurisdiction over real estate, which is not clearly defined as private or public, personal or investment property, along with banking and insurance regulation by other federal and or state agencies. This seems dramatically overreaching. Moreover, there is very little clarity about what assets within these asset classes would be included/excluded.
As small business owners, we try to keep our fees low and service high in adhering to the fiduciary standard. Another layer of regulations and is likely to escalate expenses and force us to hire and train more talent.
This is an undue hardship for small businesses that try to keep consumer fees low and service at the Fiduciary Standard.
Having considered the major facets of Rule 3290, I strongly believe that it should not be adopted.
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Stavis Wealth Transfer Solutions Comment On Regulatory Notice 25-05
Dear Ms. Mitchell,
I am the owner of a Registered Investment Advisory firm in Houston, Texas, with five employees and a registered representative of an unaffiliated FINRA member firm.
My position is that rule 3290 in regulatory notice 25–05 would duplicate oversight, and the inefficiency is likely to create unnecessary complexity for RAA’s, unaffiliated Broker Dealers, and most importantly, valued clients.
Client confidentiality is the cornerstone of our business, and their information is protected under federal law, specifically Regulation Capital S P. State privacy laws also protect the confidential information of investment advisory clients.
I have read the proposed rule 3290, and it would appear that there are myriad of conflicting rules and confusion. This is likely to confuse clients and advisors alike, making it difficult for our business to operate and for clients to have clarity and confidence.
As Fiduciaries, we are already subject to the highest standard of conduct. The imposition of overlapping yet unclear FINRA rules creates a burdensome, duplicative regulatory environment and serves no purpose other than expanding FINRA’s jurisdiction.
Also, the proposed rule claims jurisdiction over real estate, which is not clearly defined as private or public, personal or investment property, along with banking and insurance regulation by other federal and or state agencies. This seems dramatically overreaching. Moreover, there is very little clarity about what assets within these asset classes would be included/excluded.
As small business owners, we try to keep our fees low and service high in adhering to the fiduciary standard. Another layer of regulations and is likely to escalate expenses and force us to hire and train more talent.
This is an undue hardship for small businesses that try to keep consumer fees low and service at the Fiduciary Standard.
Having considered the major facets of Rule 3290, I strongly believe that it should not be adopted.
Kind Regards,
Deborah Stavis
Founder & CEO
Stavis Wealth Transfer Solutions