June 2, 2018
1. Overall, do you find the Relationship Summary useful? If not, how would you change it? If so, what topics and how can they be improved?:
The summary excludes investment options that do not use a RIA or Broker-dealer, such as dealing directly with a mutual fund family such as Vanguard, purchasing stock through a direct stock purchase plan, or discount brokers who only act as custodians and order takers. The dual option suggests these are the only two options.
2. How useful is each section of the Relationship Summary? Please consider explaining your responses in the comments:
a. Type of Relationship and Service: Not Useful: Focus is on RIA options, responsibility, and compensation
b. Our Obligations to You: Not Useful: "Best interest" is an impossible standard. Brokers need to inform investor of relevant information in a manner they can understand, and let the investor decide.
c. Fees and Costs: Very Useful:
d. Comparison to different account types: Unsure: Did not see it. Was it under Types of Relationships?
e. Conflict of Interests: Useful: Appears incomplete
f. Additional Information: Very Useful:
g. Key Questions to Ask: Useful: Why not require RIA to provide answers in writing without requiring investor to ask?
3. Please answer the following questions. Please consider explaining your responses in the comments:
a. Do you find the format of the Relationship Summary easy to follow?: No:
b. Is the information in the appropriate order?: Some what:
c. Is the Relationship Summary easy to read?: Yes:
d. Should the Relationship Summary include additional information about different account types?: Yes:
e. Would you seek out additional information about a firm's disciplinary history as suggested in the Relationship Summary?: Yes: If I were using this type of relationship.
4. Are there topics in the Relationship Summary that are too technical or that could be improved?:
There is no mention of common "Know Your Customer" that should be asked and which should impact the nature of the relationship. Types of Relationships appears to include different things that are better covered elsewhere. Obligations appear to have been written by the RIA who wants to minimize the list. It should probably be longer. Fees and Costs are often hidden in ways the investor does not know to ask. Although this list is lengthy, it appears incomplete. Conflicts of Interest is another of those issues with hidden information. I don't see how an RIA can act as principal and also avoid conflict. Therefore, I don't understand how it is even a possibility, even if they disclose the possibility to me.
5. Is there additional information that we should require in the Relationship Summary,such as more specific information about the firm or additional information about fees? Is that because you do not receive the information now, or because you would also like to see it presented in this summary document, or both? Is there any information that should be made more prominent?:
Investor obligations should probably be put into a separate section. If some of those obligations are not easily performed, then performance guidance would be helpful.
6. Is the Relationship Summary an appropriate length? If not, should it be longer or shorter?:
Four pages is pushing the length that people would be willing to read. Perhaps that can be addressed by having transaction based on one document, and asset based on a separate one.
7. Do you find the 'Key Questions to Ask' useful? Would the questions improve the quality of your discussion with your financial professional? If not, why not?:
Good questions I wonder why I need to ask them. They should be providing me with this information as part of intact and periodic review without the need for me to ask.
8. Do you have any additional suggestions to improve the Relationship Summary? Is there anything else you would like to tell us?:
The RIA or B-D should be given first chance at correcting a problem. Most people will not know when to call the SEC, and when to call FINRA. In some states, there may also be some state regulatory resources.