Jul. 31, 2018
Dear SEC representative,
S7-07-18 for Regulation Best Interest
The introduction of a new “Regulation Best Interest” standard that would allow broker-dealers to say they act in the “best interests” of their clients, without actually being subject to a full fiduciary duty to require it
S7-08-18 for Form CRS/Titles comments
A Form CRS disclosure that is supposed to explain the relationship between advisors and brokers, but uses confusing language that blurs (instead of highlighting) the distinction between who can and should legally give advice, versus who is compensated for the sale of a product. This would allow hybrid broker-dealers to state that they are “financial advisors” without any requirement to disclose when they STOP wearing their advisor hat and switch into a sales role
S7-09-18 for the RIA Harmonization proposals
This potential new requirement would require independent RIAs to have national continuing education requirements, and potential capital requirements in order to start or maintain an RIA. These requirements would raise an additional compliance barrier to those who wish to start RIA serving clients in the accumulation phase of life.
Thank you for your time and consideration,
Sincerely,
--Joe