Subject: Standards of Conduct for Investment Advisers and Broker-Dealers
From: Marilyn Lafreniere

July 21, 2017

Securities and Exchange Commission,
This is a simple matter of knowing right from wrong, and individuals doing the "right" thing. I am just amazed every time I recognize that I am living in a culture where that norm of right and wrong has been suspended in favor of self interest. Nowhere is this more obvious than the financial sector, and I do not understand how such unethical behavior ever was allowed as a standard practice. Those who allow this and look the other way are as guilty as those reaping the ill gotten profits. When investors turn to financial professionals for advice, they expect and deserve advice that’s in their best interests. But some “advisers” who work for broker-dealers are not always required to meet that standard, and some may even be paid in ways that reward them for putting the interests of the firm ahead of the best interests of the customer. Investors lose out on tens of billions of dollars in investment returns each year when these conflicted advisers recommend inferior investment products that pay them more. I urge the Securities and Exchange Commission to adopt new rules, modeled on the Department of Labor’s rule for retirement investment advice, requiring brokers to act in their customers’ best interests and requiring firms to reduce conflicts that undermine that standard. Investors don’t need more boilerplate disclosures, they need real protections from industry practices that put their financial well-being at risk.
Marilyn Lafreniere