Subject: File No. S7-08-18
From: Brandon Grundy
Affiliation: CFP and NAPFA member

April 25, 2018

Your efforts to make brokerage and investment advisory options easier for the retail investor to understand is laudable. However, what many retail investors need most is well-rounded financial advice (and often investment management/advice) from a skilled third party who can provide that advice with as few conflicts of interest as possible. They need clear information to more easily evaluate their options.

Your proposals fall short of this. The Relationship Summary, as proposed, seems like it would be too general and not allow for enough education and differentiation between the concepts of fiduciary advice and "best interest" (or "suitability standard") advice.

Additionally, the proposed Summary language fails to reference and describe other services the retail investor is likely seeking (financial planning, retirement planning, budgeting, college planning, etc). Retail investors are often seeking this kind of advice from the person they are interviewing and it can be very unclear and confusing if the professional is willing, able, and compensated to provide this kind of assistance and advice.

Fundamentally, what the retail investor likely wants to know about the person they're sitting across from is:

1) How can this person help me?
2) Can they help me?
3) What's their agenda?
4) What should I know but don't know enough to ask the right questions?

The answers to these questions need to be as clear as possible, and not require the retail investor to do a deep-dive investigation into available options. Adding more descriptive language to the Summary to differentiate these service concepts would be helpful.