Subject: S7-0818
From: Tom Rogers
Affiliation: Portland Financial Planning Group, LLC

Jul. 26, 2018

Good morning Chairman Clayton,

I'm writing to you today to express my concern that the proposed SEC rule reflects the view that brokers and registered investment advisors are virtually the same in how they conduct business.

With all due respect, that is incorrect. In refining the proposed SEC rule, I request that your staff recognize the major distinctions between brokers and RIAs, and tailor regulations accordingly.

Cordially,

Tom Rogers

Thomas S. Rogers CFP®
Principal
Portland Financial Planning Group, LLC