August 1, 2018
Dear SEC,
I am the founder and owner of Everlong Financial, a fee-only, registered investment adviser firm in Austin, TX. I am a Certified Financial Planning professional and have worked as an adviser for 14 years.
I started my career as a broker/dealer with my Series 6 and 63 licenses. After 5 years, I dropped my licenses, earned my CFP designation, and have been practicing as a registered investment adviser for the last 10 years.
Having seen both sides of the Broker/Dealer world and now the Investment Adviser world, I hope that my comments will help provide some insight with the proposed Form CRS Summary Amendment.
There are great differences between a customer and a client, where a customer is buying a product and a client is buying a service. This distinction should be made clear to the public when deciding to work with a Broker/Dealer (providing a product) or an Investment Adviser (providing a service/advice). It should also be made clear to the public the scope of the service being offered - again, a transactional sale or ongoing advice. The compensation method should also be clearly stated - commission from the sale or fee for the advice. Finally, the standard of care - suitability for Broker/Dealers and fiduciary standard for Investment Advisers as outlined in the 40 Act. I strongly believe that this type of transparent approach will greatly benefit the public.
I strongly support the comments put forth by Michael Kitces in his public letter to the SEC with regards to Form CRS and hope the Commission takes his comments into consideration for the benefit of the public.
https://www.kitces.com/blog/public-comment-letter-sec-advice-rule-regulation-bi-form-crs/?utm_campaign=Member Communicationsutm_source=hs_emailutm_medium=emailutm_content=64855484_hsenc=p2ANqtz-_qMkgyrf_13r3THenbkKKvSbMDftM6gPIqBhlSl3-J8DUZNrRmptb8aUwaaEf5nCl5JaemryGzk3nc7Alft0YeLdO7qPySTLsujsNDCqIeK7YgBY0_hsmi=64855484
Thank You,
Alex Yeager