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U.S. Securities and Exchange Commission

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


Modified: 08/01/2018