Subject: IA-BD-Conduct-Standards
From: Robert Ramos

June 18, 2017

Good morning,

(I tried to submit this via the webfom…but kept getting an “Access Denied” error)

Let me open by stating that advisors should always put their clients interests ahead of their own. Let me also state that this basic approach is not that hard to follow.

However, the DOL's Fiduciary Rule is a mess and does nothing to help investors (large or small) or advisors (or planners or whatever we are calling ourselves today).

Having the DOL manage a fiduciary rule that applies only to IRAs is like asking the FBI to manage speed limits. One make be able to make the technical argument that the agency has jurisdiction...but the agency doesn't have the experience or knowledge base to create/manage the rule nor does it have the systems or personnel in place to enforce or manage the rules.

So we end up with a mess like the DOL fiduciary rule.

The SEC, possibly in combination with FINRA and state securities agencies, is the obvious regulatory body to establish and oversee fiduciary responsibilities of advisors, planners and reps. Fiduciary regs that cover all types of accounts...not just IRAs.

The DOL approach is not just is wrong headed.

It is my hope that the SEC will take on this role as it is the role it was created to fill.

It is also my hope that the SEC will create a common sense rule intended to help all (including small investors and the average well intentioned, ethical advisor) instead of relying on zealots and propagandists like the DOL obviously did when it manufactured its rule.

Please add us to your social media contacts:

Robert T. Ramos CFP®, ChFC®, CASL®  
Managing Partner and Financial Advisor

Wealth Management Partners, LLC  
603 Post Office Rd Suite 106
Waldorf, MD 20602