July 19, 2018
As an independent financial advisor for 25 years I understand and appreciated SEC research in the best interest of the client. I have always kept in mind the best interest of the clients. Clients come to someone like me because of my knowledge, experience and expertise. They have no clue what to do. My recommendations have never been recommended and never will be recommended based on my own financial gain. To be very honest, when I recommend a specific investment idea for my client I don’t even know what the commission would be. I am a commission only advisor, and the advisory option just does not fit with my size of clients. If I recommended a mutual fund, it is usually buy and hold, because you just can’t continually move around the funds. Never have and never will, and yet I do visit with clients on a regular basis to discuss how things are going. Maybe sometimes things have to be tweeked, but not with discussing the options. I have always shown my clients the fees listed in a prospectus. I also have recommended different types of annuities and/or alternatives. Gathering information from my clients, and coming up with a recommendation does take time, and I appreciate being compensated for my service. Actually, as you may know it is a necessity. If people expect there is no cost for my service then we are not a good fit.
I also urge the SEC to pay close attention to the cost-benefit analysis conducted with regard to Reg BI and ensure that any additional regulatory requirements are tailored closely to their intended purpose and do not result in additional requirements that will ultimately limit my ability to work with my clients and will negatively impact their access to a variety of products and services I can recommend to help meet their needs.
I would appreciate that you would consider my thoughts and comments as you continue to develop the Best Interest proposal.
Freitag Financial Services
208 N Main Street
PO Box 157
Monticello, WI 53570