Subject: File No. S7-08-18
From: Deborah Meyer, CPA, CFP(R)
Affiliation: NAPFA, XY Planning Network, Fee-Only Network, AICPA

August 5, 2018

I am concerned with the proposed Form CRS disclosure that is supposed to explain the relationship between advisors and brokers. Instead, the language is confusing and it blurs (rather than highlights) the distinction between who can and should legally give advice. Fee-based advisors are compensated for the sale of a product, while fee-only advisors like myself are compensated for guidance that is in the client's best interest. I do not have any incentive to direct a client towards an expensive investment product that is "suitable" rather than one in his or her best interest.