Jul. 26, 2018
The Honorable Jay Clayton
Chairman
The United States Securities & Exchange Commission
As a fee-only planner and advisor, I wish to comment on the proposed rules for conduct standards for broker-dealers and investment advisors.
I work with a variety of clients on retirement planning, estate planning, insurance needs, and investment objectives. I sell no products, and my compensation is paid entirely by my clients.
I am a fiduciary for my clients, and must inform them of any potential conflicts. I also inform them of all fees and expenses which may be incurred in our relationship before entering into that relationship.
I spend approximately 60% of my time in planning activities, and 40% in dealing with investments. My recommendations are not limited to one company's offerings, and I have no financial relationship with any product provider I recommend to my clients.
I feel that it is imperative that a clear line be delineated between brokers and advisors such as myself - consumers and regulatory agencies should recognize the clear differences and not treat them identically.
Thank you,
Michael Harris, CFP(R)
Blue Rock Financial Services, Inc.