August 6, 2018
As a Certified Financial Planner (TM), Enrolled Agent and Registered Investment Advisor in the State of California, I provide each of my clients with extensive written and verbal explanation of my services, the fees for my services, and the fiduciary duty I adhere to in each client relationship I undertake. I do this by providing each client a Form ADVII with annual updates as well as updates whenever there is a material change in my business. I also provide a copy of my firm's privacy policy and a lengthly advisory agreement, reviewed and signed by all parties which describes the scope of the advisory engagement and includes a clear statement as to the fiduciary nature of the advice that I offer.
As a fee-only registered investment advisor, I do not charge a fee based on assets under management. My clients pay me for my financial advice. This advice pertains to each client's unique financial situation and may or may not include investment advice. I do not receive commissions on the sale of any products.
The proposed CRS rule as put forth in s7-08-18 will serve further confuse the public as to the distinction between broker-dealers and registered investment advisors. Selling of products is distinctly different from offering advice that is fiduciary in nature. I encourage the SEC to further review this proposal and to refine it in a way that clarifies rather than confuses the public as to the distinction between sales and advice.