Subject: File No. S7-07-18
From: Maxwell Patrick, Jr.
Affiliation: District Operations Manager SW Sales District ($150M annual revenue) Retired

April 19, 2018

-The SEC has chosen to call this publication "Regulation Best Interest". There is no ambiguity here, "Best" means "better that any other" interest, including that of the broker, advisor, or salesman. There shouldn't be any caveats. Unfortunately, the SEC's proposed regulation also includes the caveat that if the broker, advisor, or salesman "...reasonably discloses to the retail customer, in writing, the material facts relating to the scope and terms of the relationship, and all material conflicts of interest associated with the recommendation...", then the investor's BEST interest is served.

So, essentially, if the broker, advisor, or salesman tells the investor "I have a conflict" then the broker, advisor, or salesman can tell the investor anything even if the advice is totally in the broker, advisor, or salesman's interest alone and to the detriment of the investor.

This seems to be a particularly egregious example of double-talk designed to mislead investors into thinking they are protected by the SEC when in fact, there is no protection at all.