Subject: S7-0818

July 29, 2018

Dear Chairman Clayton,

I am writing to you today to provide input on the proposed SEC rule on the rules on conduct standards for brokers and investment advisors. As I read it, the proposed rule reflects the view that brokers and advisors conduct business in the same manner. Having started my career as a broker but having spent the last 18 years as a fee-only advisor, I can assure that they do not. Here are a few of the differences:

I appreciate your time and hope that you will reconsider the proposed rule in a way that will differentiate between advisors and brokers.

Thank you.

Bob Rall
Robert J. Rall, CFP®
CERTIFIED FINANCIAL PLANNERTM