August 7, 2018
While I appreciate the SEC's attempt to regulate the use of the term "Advisor" to only those affiliated with RIAs, the usage of the various terms that include the word "Advisor" are still easily problematic. Given that the word "Representative" would be the most accurate (and grammatically correct) way to refer to an Investment Advisor Representative, given that distribution is their primary function, I would countenance the SEC to distinguish those in financial services who actually use a peer-tested, fully documented process under the auspices of a certifying body to indicate a professional stature and accountability among stakeholders that can not be obscured by amorphous references to what might be deemed "advice" - in short, "Financial Planner" should be a protected title, regardless of how you try to regulate the word "Advisor". Just because I "advise" you to buy into something that has 60% of widget A and 40% of widget B does not make me an "Advisor" - hence the confusion. However, if an appropriately certified Financial Planner takes you through a standardized planning process that results in a documented Plan being produced, than you are working with a bona fide Financial Planner. Now THAT is something worthy of being acknowledged by the SEC via title recognition.