Subject: File No. S7-07-18
From: Jacob Williams, Ph.D.
Affiliation: Director of Planning and Research at The Helmstar Group

July 20, 2018

This new regulation on best interest is a move in the right direction, but it's not enough.

Best interest only at the time an investment recommendation is made is VERY different than always acting as a Fiduciary which includes a duty of care and duty of loyalty, among other things.

I have to ask myself whether I'd be comfortable sending my mom and dad to someone who only has a suitability standard plus a little more with the best interest language. Let's get everyone on the same page ASAP instead of taking baby steps. I would feel more comfortable knowing my mom and dad went to someone who was held to a Fiduciary duty. It seems common sense for anyone dealing with someone's wealth, which affects every aspect of someone's life, not only monetarily, to be held to a high standard. I can't imagine a medical doctor being held to a suitability standard.

Research has shown that disclosures don't work as intended. Anyone dealing with securities and financial advice should be held to a common high standard.

This should be an opportunity for the SEC to take a stand on doing what's right as opposed to doing what's in the financial service's best interest.

Thank you