Subject: Standards of Conduct for Investment Advisers and Broker-Dealers
From: Charles Prescott

July 21, 2017

Securities and Exchange Commission,
When investors turn to financial professionals for advice, they expect and deserve advice that's in their best interests. The SEC rules should be clear that an "advisor" has a fiduciary responsibility. It's all about the client, not the "advisor's" payday. 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.
And recall that untold thousands of retiring employees have never had to deal with the puzzle of investing or managing substantial sums of money, and certainly not a windfall that could be 100's of thousands of dollars. They especially need assurance that the advice is in their interest, and not anyone else's.
Charles Prescott