Subject: File No. S7-07-18
From: Ethan S Braid, CFA
Affiliation: President, HighPass Asset Management

June 28, 2018

Regulation Best Interest should be discarded. The proposed regulation will create even greater investor confusion and allow brokers to be the wolf in sheep's clothing. I have been in this industry for over 20 years and have run a fee-only advisory firm for the last 6+ years. Prior to founding a fee-only firm, I worked for over a decade at two to the largest broker dealers. In my career I have met with and counseled hundreds of wealthy individuals. Some with net worth over $100 million. I have found that very few investors understand the differences between terms like "fee-based," "fee-only," "broker" or "fiduciary." While there are huge legal differences between the suitability standard which brokers follow and the fiduciary standard followed by advisers, most investors do not know the differences. By passing this proposed regulation, brokers will be able to act and look like fiduciaries and at the same time still be able to sling products for commissions. How is this in the best interest of a client? Investors do not read the complicated prospectuses and ppms provided to them by brokers selling products. Who in their right mind believes that by simply requiring brokers to give more disclosure (which will be complicated and not understood by most investors) they can still sell commission products and the sale can somehow be in the client's best interest? Rubbish. Pass this proposed regulation and you only harm the investing public. Soon you will have thousands of salespeople at all of the largest broker dealers telling investors they act in the best interest of their clients - just like RIAs do. But the wizard behind the curtain will still be there and the brokers will still be able to get paid just like they always have. Somehow however their sales activity will now be in the client's best interest? Who decides then what is in the best interest of the client? The broker might say selling ipos, limited partnerships and investment bank products (structured notes) The RIA might say paying transparent fees and investing in stocks etfs with low turnover, tax efficiency and a focus on long term investing. Who will the investor believe? They are both acting in the "best interest" of the client, correct? Here is a simple way to protect investors:

1. Disallow the term "FEE-BASED" in all marketing materials.
2. Anyone who is series 7 licensed must use the title:
3. Anyone who is dual registered must use the title:

Simple and effective. Investors do not understand the differences between brokers and advisers and this proposed regulation makes the confusion even worse.