Subject: File No.
From: Anonymous Anonymous

June 23, 2017

I believe the fiduciary rule has good intentions, but will have unintended consequences. Since semi-implementation we have seen the smaller investor get pushed aside or their risk objective decided for themselves. Our group has worked with retail clients for over 40 years and built a great business by focusing on the clients needs first. We use both fee and commission base accounts based on their trading, advice needed, risk and investment objectives.

Since implementation of the fiduciary rule, we have had to restrict client minimums as the risk is not worth the reward of lower fee's or lawsuit exposure. Our firm has held stricter policies of what type of investments (concentrations of stocks) we can adhere to, ultimately making almost every account a target date fund. This has led to the opposite of a fiduciary duty for some clients individual objectives.

I believe this rule has increased cost to smaller clients, steering advisers to fee based arrangements or SMA accounts, and limits options for both adviser and client. While it has helped the trend toward advisory business, that is not the best practice for all clients. Each individual investor has their own risk, trading and investment objective and advisers should comply to that fact.

I support a fiduciary rule, but the current dol is a one size fits all and disrupts the retail client-adviser relationship. This should be studied and rectified based on facts (United Kingdom for example and small investors left behind) and not political agenda.


Anonymous Registered investment advisor.