August 6, 2018
The first thought is that the SEC should enforce all of the Investment Advisers Act of 1940 which would seem to cover most of the issues with properly licensed individuals. The SEC should not in my opinion invent a new standard for RRs, RIAs or IARs that would probably create more confusion.
My second thought is that without including "Fixed Indexed" insurance and Annuity sales by insurance-only producers it would have little impact on the sale of products where most of the best interest issues occur. I have long believed because of the way these products are sold they should have more regulatory scrutiny than most insurance departments can give them.
The biggest issue I see is insurance producers who represent themselves as financial planners or have affiliated with an RIA firm so that they talk about investments but sell almost exclusively "FIAs" as investments. I also believe that anyone else who may want to give investment advice should likewise be prohibited from referring to themselves as "advisers" unless they have a CFP or perhaps CPA and are appropriately licensed as an investment advisor RIA or IAR.
Brokers should do more than just act and look like fiduciaries but, at the same time still be able to selling products for commissions where appropriate. Today as an example, I met with an older couple and their two kids. They owned eight annuities sold over a 4 year period. A couple of the annuities seemed appropriate while the others seem to have been sold for commissions only and with very long surrender periods.