“If you have a vague standard and best interest isn’t defined, even if you revisit the summary, how do you communicate what best interest is?” Certner asked.
Cetera said it is aware there is push back against the proposals, but cautioned the SEC against waiting for a consensus. “Our review indicates that a large number of the comments regarding Form CRS found fault with it, for many different reasons. Some considered it too short, some too long, some found it too complicated, and others thought it too simplistic. We offer the following perspective: Nothing is perfect. To expect complete agreement from the universe of parties who have views on standards of conduct for financial advisers, especially with respect to anything that represents such a substantive change to the existing regulatory regime as Form CRS is not realistic,” Quinn said.