The following Letter Type A, or variations thereof, was submitted by individuals or entities.
Letter Type A:
To The Honorable Chairman Clayton,
I appreciate the work you are doing on creating an SEC rule to protect consumers of financial advice. I'd like to express that while I think merely taking on this task is a great start, I don't think the current draft does enough to clearly differentiate between advisors and brokers. For this reason, I would like to provide you with my perspective as an advisor on why we are different:
- I am a planner and advisor to my clients. The major focus of my services is holistic/ life/financial planning. I spend about 75% of my time on planning, as opposed to just 25% of my time on portfolio design and management.
- My colleagues and I are not hired to sell products and are not trained in sales; they are hired to advise clients and are trained in finance and in advice, and have the CFP®, CFA and CPA designations.
- As an RIA, I render fiduciary advice in intimate relationships of two; brokers can only offer incidental advice in sales relationships of three.
- My investment product recommendations are wide and deep and not limited.
- I minimize conflicts by only receiving compensation from client fees; I do not accept commissions or other third-party payments in connection with my recommendations.
- The fees and the underlying investment costs clients pay are transparent and clear. I offer estimates and annual reports of clients' fees and expenses. There is no confusion: My clients know what they've paid and what I've earned.
- I do not sell insurance or proprietary products, or engage in principal trading.
- If I have any material conflicts, they are clearly listed on my ADV.
Again, I appreciate all of your effort spent on this rule and look forward to seeing the next iteration of the rule.
http://www.sec.gov/comments/s7-08-18/s70818-typea.htm