Subject: File No. S7-08-18
From: Ron Shepherd

June 20, 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?:
Overall, the Relationship Summary is useful.

2. How useful is each section of the Relationship Summary? Please consider explaining your responses in the comments:
a. Type of Relationship and Service: Useful: Overall, the Type of Relationship and Service is useful.
b. Our Obligations to You: Useful: Useful, as far as it goes.

However, I would find this much more useful if the agent (broker-dealer or investment advisor) were REQUIRED to act in the client's best interest (fiduciary responsibility) in each transaction, with specific penalty actions when they do not so act (including financial recompense).

Second, in disputes or appeals both broker-dealers and investment advisors should be required to allow clients access to courts of law. Blanket requirements for arbitration only should be disallowed.
c. Fees and Costs: Useful: Useful as far as it goes.

However, human nature being what it is, and conflicts of interest being endemic in the industry, I would find it much more useful if the agents (both broker-dealers and investment advisors were REQUIRED to act in the clients best interest (fiduciary responsibility) in each and every transaction.
d. Comparison to different account types: Useful: Somewhat useful, but more for fulfilling their CYA requirements.
e. Conflict of Interests: Useful: Useful in that it spells out some of the obvious conflicts of interest.

However, it would be much more useful if agents (both broker-dealers and investment advisors) were REQUIRED to act in the client's best interest (fiduciary responsibility) at all times.
f. Additional Information: Useful: Minimally useful.
g. Key Questions to Ask: Useful: Especially useful for novices to investing and useful reminders to more experienced investors.

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?: Somewhat: Beginning to approach the realm of too much information, but better this than nothing at all.
b. Is the information in the appropriate order?: Somewhat: Can't find fault with the ordering of the information.
c. Is the Relationship Summary easy to read?: Somewhat: Mostly, but then I have a college education and years of investing experience, both good and bad. Can't speak for someone of lesser education or experience.
d. Should the Relationship Summary include additional information about different account types?: No: Probably not, as long as account type information appears in its own section, and is appropriately referenced.
e. Would you seek out additional information about a firm's disciplinary history as suggested in the Relationship Summary?: Yes: Absolutely. And the easier it is to access, the better. An website seems to be a useful source.

1. As long as the website is complete, i.e. covers all types of relationships, accounts, and transactions.

2. As long as ALL disciplinary history is recorded there, with all events listed together with their resolution, whether in the client's or the agent's favor.

4. Are there topics in the Relationship Summary that are too technical or that could be improved?:
I personally am not having difficulty understanding the topics, noting that is based on both a college-level education and many years of experience, both good and bad.

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?:
Knowing about fees and conflicts of interest and disciplinary history falls short when a client does not understand how to evaluate them. I am arriving at a useful level of such understanding after 30+ years of experience, and huge losses because of a lack of such understanding. Had this documentation been available in my early years, it might have at least stimulated some investigation on my part, but a sufficiently-trained agent can (and has) overcome information and education, much as "snake-oil salesman" did in the 1800s in medicine.

So is this information useful? Yes. Will it overcome the agent's higher level of information and ability to fast-talk the client? Not a chance.

What is needed is a firm rule of fiduciary responsibility with access to courts of law to firmly enforce this discipline. Plus a full disclosure of an agent's history, regardless of firm for which they are currently working.

6. Is the Relationship Summary an appropriate length? If not, should it be longer or shorter?:
A reasonable length.

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?:
A useful beginning. But an experienced agent will be able to overcome any skepticism on the client's behalf, especially when the investor is a novice.

8. Do you have any additional suggestions to improve the Relationship Summary? Is there anything else you would like to tell us?:
Add the requirement for fiduciary responsibility for both the broker-dealer and the investment advisor.