Subject: File No. S7-09-18
From: Benjamin Prybutok, 8567019195
Affiliation: Lutcf

June 28, 2018

Having been a registered representative for over 30 years and affiliated within every distribution channel in the financial services industry, from Merrill Lynch and Smith Barney, to Insurance broker dealers independents as well as the banks ( First union). Dealing with the public or Retail as it is called for over 30 years has not warranted me to have any disclosures on my u-4 that are complaints by the public, customers in any market environment.
This advice standard is rather easy to implement within any firm or broker dealer. Firms and broker dealers need or will have to be required to adhere to a full service platform within their platform. For example I am affiliated with Allstate Financial Services therefore they should be required to allow for an RIA platform as well as lifting the restrictions to allow the aeries 7 licensed producers to provide etf's, spdrs as well as a more broader selection of both fixed and variable annuities. In order to service the broad public a firm should be required to adhere to a standard for the investing public with like products and vehicles.
Not different than a manufacturing company being required to adhere to ISO certifications quality standards for the sale of their products to large industry. If a Broker dealer is small and has no scale then they may have to merge or spend the money to be in business.
More importantly, the overall standard is a state of mind and an adherence to do things that are in the best interest of the customer. However sometimes and often the forms themselves are not positioned properly to serve the broader public and are limited to what they are able to or may want to do and that is where the conflicts occur.
Firms themselves and the industry will need to change and the distinction between broker dealers and RIA's will be seamless and there will be less conflicts.