Subject: File No. S7-07-18
From: Leo O'Connor, Jr
Affiliation: Financial Planner, Visions Federal Credit Union

June 20, 2018

To put a client's best interest first then the professional should know the client's entire financial situation. Under your rule a professional may be asked whether a roth or traditional ira is better for a client and the planner gives them an answer, the choice that is the better of the two, ignoring the fact that an IRA in the first place wasn't in the best interest of a client with credit card debt and that wasn't taking advantage of an employer match.

And let's be honest, Series exams are completely failing to prepare the professional for actually giving advice to a client. How can they know what is in the client's best interest if they are ignorant of what the options are themselves? At a minimum, there needs to be more education for professionals just trying to give investment advice. The book Asset Allocation by Roger Gibson should be required reading. And limitations must be put in place, and enforced, on the titles professionals can use. How is a member of the public supposed to determine if they should use an investment advisor, an investment manager, an investment consultant, a financial consultant, a financial advisor, a financial adviser, a financial planner, a wealth advisor, etc. I think the term Financial Planner, for one, needs to be reserved for those that hold the CFP designation. For anyone that just holds a securities license they should be required to call themselves an investment/financial salesperson. Because let's face it, no one educated on the matter would hire someone that just holds a series license when more qualified professionals, proven by the credentials they hold, are out there. Why would I go with a Series 7 rep over someone with a CFA to run my investments? I wouldn't.

And a client should be able to hold a professional to the highest (fiduciary/best interest) standard at ALL times. And if a series rep wants to lower the chances they get sued they shouldn't advocate to water down the standard but educate themselves so they are able to rise up and meet the new standard with ease.