The second and final phase of the Client Relationship Model (CRM) will take effect on July 15, 2016, a scant nine months away. This date marks the culmination of a four-year effort to build a comprehensive regulatory framework for the client-advisor relationship.

The IIAC has started to think about where do we go from here. Some regulators believe the rule framework does not go far enough to meet the clients’ broad needs, and that more regulation is the answer.

My guest column, which appears in the November edition of Investment Executive, sets out some preliminary thinking as to where policy should go. I argue that more rules is the least productive approach after years of extensive rule-making and consultation to build the CRM rule framework. Rather, I write, the focus should be on increased regulatory oversight of non-SRO registrants to ensure full compliance and a level playing field; on developing industry best practices; and on improving the culture of firms and advisors. Indeed, I believe the latter is the most productive direction, but it must be done carefully, placing minimal burden on firms. 

You can access my opinion editorial by clicking here.