Subject: File No. S7-08-18
From: Gerald B. Levin, Ph.D.

June 28, 2018

If you genuinely want consumers to know the difference between fiduciaries and commissioned salespeople, you will require:
1. fiduciary registered investment advisers to call themselves "fiduciary registered investment advisers" and
2. stock brokers and insurance salespeople to call themselves "non-fiduciary financial product sales representatives".

Also, the investment advisory agreement between the client and the:
1. firm that employs the fiduciary adviser must clearly state that the adviser is legally required to put the interests of the client ahead of those of the adviser, his/her family, and his/her firm.
2. firm that employs the sales rep. must clearly state that the sales rep.'s duty to his/her firm and to himself/herself takes precedence over his/her duty to the client, with some safeguards against excessive abuse (e.g., "suitability" requirements). Where applicable, that contract should list potential conflicts of interest, such as incentives to "recommend" mutual funds with high sales commissions.