An Update From Washington ACR#88750

Vision: Access to Advice Mission: Advocacy

For Broker-Dealer Use Only Your Voice in Washington For Broker-Dealer Use Only

Advocacy Initiatives 12b-1 Fees Independent Contractor Status Dodd Frank Implementation DOL Fiduciary Proposal

12b-1 Fees

Independent Contractor Status

Dodd Frank Implementation

Regulatory Arbitrage In 2011, FINRA examined 58% of BD firms The SEC examined only 8% of RIAs (average exam cycle of once every 13 years) 40% of RIAs have never been examined See testimony of Caro di Florio, SEC Director of the Office of Compliance Inspections and Examinations, before the U.S. Senate Committee on Banking, Housing and Urban Affairs Subcommittee on Securities, Insurance, and Investment (November 16, 2011) at http://sec.gov/news/testimony/2011/ts111611rk.htm.

FSI Supports Balanced regulatory supervision Clearly articulated rules of conduct Effective client disclosures

DOL Fiduciary Proposal

Threats to Your Business No commissions on IRAs No grandfathering Must transition to fee-based (advisory) = higher costs for clients Many smaller clients priced out of market for advice altogether

Get Engaged

For Broker-Dealer Use Only David Millican, Atlanta, GA Bob Carson, Maple Lawn, MD Jeff Gitterman, Iselin, NJ Mike Hensley, Raleigh, NC Mark Robare, Houston, TX Mark Mettelman, President & CEO Phil Blancato, CEO & President, Ladenburg Thalmann Asset Management Adam Malamed, COO, Ladenburg Thalmann Financial Services Dick Lampen, President, CEO, Ladenburg Thalmann Financial Services For Broker-Dealer Use Only

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