FSI’s 2019 Advocacy Priorities
The Financial Services Institute’s (FSI) mission is to ensure that all individuals have access to competent and affordable financial advice, products and services delivered by a growing network of independent financial advisors and independent financial services firms. Our top advocacy priorities include:
ISSUES IMPACTING CLIENTS
Workable Best Interest Standard of Care: We will continue to support efforts to finalize Regulation Best Interest (Reg BI) so it creates a standard of care that improves investor protection without significant increases in costs that deprive investors of access to financial planning services and advice. We will oppose state efforts to implement fiduciary standards or fiduciary disclosures, which will complicate compliance and confuse investors without contributing to investor protection.
Retirement Security Solutions Provided by the Private Sector: We support reasonable efforts to improve the ability of Main Street Americans to save for a financially secure retirement in response to the looming retirement security crisis. Our efforts will include advocating to restore the deductibility of advisory fees, supporting state Multiple Employer Plans and voluntary state-run retirement plans.
Prevention of Financial Exploitation of Vulnerable Adults: We will continue to support the adoption of the NASAA model rule protecting seniors from financial exploitation.
ISSUES IMPACTING INDEPENDENT FINANCIAL SERVICES FIRMS & ADVISORS
Independent Contractor Classification: We will work to educate states on the independent broker-dealer (IBD) model as more states make independent contractor inquiries of our members. In addition, we will provide our members with best practices on worker classification challenges. Furthermore, we will continue to work with the “I’m Independent” coalition in California.
Reducing Burdens on Business Entities Operated by Financial Advisors: We advocate for the modernization of rules prohibiting the payment of commissions directly from a broker-dealer to an unregistered entity operated by a financial advisor. Additionally, we support regulation and legislation that reduces the burdens on small businesses, particularly Association Health Plans.
Level Playing Field for Firms and Financial Advisors (Harmonization): We support the harmonization of regulatory requirements for investment advisers and broker-dealers who provide similar services to the investing public.
ISSUES IMPACTING THE FINANCIAL SERVICES INDUSTRY
High-Risk Brokers: We support reasonable regulatory efforts to protect investors from financial advisors and firms who have a demonstrated history of harming investors or have failed to pay arbitration awards, including coordination among state and federal regulators to permanently ban bad actors from working with the investing public in any financial capacity whatsoever.
Federal Cybersecurity Requirements: We support legislative efforts to create a national data breach notification requirement. We will work to ensure regulations related to cybersecurity are not “one size fits all” and take into account the unique aspects of the IBD model.
Combating Regulation via Guidance or Enforcement: We oppose regulatory enforcement activity that is predicated on staff guidance or that creates new requirements without the benefit of notice and comment. We will work to raise concerns with the SEC’s share class disclosure initiative and follow on enforcement activity.