July 24, 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?:
Yes.
I like the side by side comparisons.
I did not notice any discussion specifically regarding bad advice other than the mention in the last paragraph under "Additional Information".
2. How useful is each section of the Relationship Summary? Please consider explaining your responses in the comments:
a. Type of Relationship and Service: Very Useful: Why limit selection of investments?
b. Our Obligations to You: Very Useful: The Fiduciary Standard option does not mention/include a reference about being fair or in the clients best interest statement, which the Broker option section does
c. Fees and Costs: Useful: Mentioning the various types of fees in general is helpful (so we would know what to ask about). The most useful thing would be a requirement to list the actual fees that affect our own personal account on our account somewhere.
Also need further explanation for wrap-fee-programs and custody fees.
It would be helpful to see a "hypothetical" Relationship Summary of the various fees and who gets paid and how much for each fee.
d. Comparison to different account types: Unsure: This section seems out of order with the Hypothetical Relationship Summary pages.
I assume you are referring to Brokerge Accounts and Advisory Accounts.
Also in an account combining the two it would seem like it could become very complicated and confusing for the client and in some cases for the broker/advisor to know which hat is being worn.
e. Conflict of Interests: Useful: The transactions comment in the fees section seems like it would also fall under the conflict of interest section.
Would need further clarification on the "acting as principle".
f. Additional Information: Very Useful: Like this section.
g. Key Questions to Ask: Useful:
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?: Yes:
b. Is the information in the appropriate order?: Somewhat: Mostly
c. Is the Relationship Summary easy to read?: Yes: Fairly
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:
4. Are there topics in the Relationship Summary that are too technical or that could be improved?:
Yes.
See answers in other sections.
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?:
Yes. Yes. No.
6. Is the Relationship Summary an appropriate length? If not, should it be longer or shorter?:
Whatever it takes.
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?:
Probably. ,
8. Do you have any additional suggestions to improve the Relationship Summary? Is there anything else you would like to tell us?:
As to the prior proposed DOL Fiduciary Rule regarding the IRA assets, we are glad it was thrown out.
We already have Financial Advisors we consider doing due diligence, etc. for us, thank goodness.
The issue we had with the Fiduciary Rule was increasing the cost because of the rule.
To try to summarize, we found out that the Fiduciary Rule would apply to all Class A shares and there would be a required additional yearly fee on total IRA assets in place of one-time up-front loads.
The new fees would apply whether the account made money or not or even loses money. The additional fees, we were told, would range between 1% to 3 1/2% yearly, paid quarterly, on total IRA assets. Doesn't sound like too much does it? However, IF you apply it to each year for the last ten years on OUR total IRA assets and figure at just the minimum 1% fee, against the earnings in each of those years, we would have been paying 19% to 25% of what was earned to the financial advisor. (Yes. we are aware of the argument: if the financial advisor was actively managing the account we would earn more. Maybe yes, maybe no And it would most likely require us to get out od our risk zone into a riskier investment zone).
Also, we think the additional fee could have had the following effects: Result in more self-management as people would drop using financial advisors, also resulting in the potential future disappearance of IRAs.
For new investors, with these fees, it seems it would be hard for their earnings to keep pace with the fees. Some other "plans" investment advisors had, we found, were to go strickly "all fee" and/or limit the customers they would take to a high amount of account assets (which would decrease any new IRA investors, too). In addition, we viewed it as a "back-door tax". Investors pay additional "forever" fees (whether accounts make money or not) to the financial advisors (who can be blamed for bad advice) and the advisors pay taxes on their additional income to the government. Overall who wins? Who loses?
Thank you for this opportunity at expression.