Subject: Standards of Conduct for Investment Advisers and Broker-Dealers
From: Jan Rowe

July 21, 2017

Securities and Exchange Commission,
I don't understand why we would go back: the investment adviser should say what he or she is making on the deal and what the person making the investment is making. This is a fair business practice. We need the fiduciary. I saw the hearings when near retirees were talked into dangerous investments beneficial only to the one trying to take their money.
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.

Jan Rowe