August 7, 2018
The Honorable Jay Clayton
Chairman
United States Securities & Exchange Commission
I have been a Fee-Only planner for 22 years, not only do I pride myself in being a fiduciary for 22 years, I am confident that the service I provide my clients is helpful, trusted and beneficial to them. The majority of my client base has been with me for 15 years or more. I provide them with financial planning (these longer relationships are focus around retirement planning). Much of the work I do is based on aligning what money they have with what they either need to achieve (basic spending) and what they would like to achieve (travel). Once I understand the strength of their spending plan, only then do I begin to analyze their portfolio and make recommendations. I do not sell products or earn any commissions. The revenue I receive is 100% from clients directly. About one-half write me a check each quarter the rest pay me from an electronic debt from their account. What they
pay is fully disclosed and understood. I am not tied to any broker, product or sales program.
I have a hard time understanding the various conversations in the industry that Brokers are the same as all advisors. Brokers do not have the freedom within their pay structure to provide the level of independent services and be free of conflicts. Brokers provide a great service (my dad uses a broker for one of his accounts) but they are not a financial advisor (regardless of what name is used). Last, Sec. Act clear stats brokers are different than advisors.
Before making changes that seem to create greater confusion to an already confusing issue (from the consumer's perspective), please consider that Brokers in their current structure do not provide independent planning services that many RIAs provide.
Sincerely,
James Milne
Milne Financial Planning
Vermont