Subject: File No. S7-07-18
From: Chris Chen

July 31, 2018

As a RIA and CFP, I am duty bound to be a fiduciary, ie act in the bests interests of my clients. I am product agnostic, with the exception of commissions based products: I believe that having an interest in the sale of a product cannot help but make you less objective.

I am fully aware that many people affiliated with broker dealers also feel strongly about acting in the best interests of their clients. However, broker dealer representatives have an inherent conflict of interest, as a major part of their compensation is through commissions. I am not saying that you cannot be an objective fiduciary when you get commissions. However, human nature being what it is,broker dealer representatives will be tempted with every client interaction to cross the line.

Unless that conflict of interest is removed, it is my firm belief that broker dealer representatives should not be allowed to deceptively represent themselves as acting in the best interests of their clients. Conversely, it is problematic per se when a product needs a commission to incent intermediaries to put it in the hands of a consumer.

Please, in the interest of consumers, do not dilute the "best interest" phrase by letting people who are incented to
sell certain products use the phrase as part of their marketing. It would be deceptive, not in the interests of consumers, and not in the interest of the industry.

Best regards

Chris