Subject: File No. S7-09-18
From: Scott D Horsburgh, CFA
Affiliation: President of Provident Investment Management, Inc.

July 21, 2018

A clearer distinction between the role of "advisors" and securities salespeople is the best way for investors to understand the type of relationship they want. Banning salespeople from labeling themselves as "advisors" goes a long way, but not far enough. There is an endless list of alternative titles that can be used to imply that a salesperson is somehow a neutral consultant. However, there is also a simple way to help investors distinguish between the two business models: require people engaged in the sales of securities for a commission to include the word "sales" in a title underneath their name on business cards and electronic communications make it a violation to imply that they are neutral consultants. Registered investment advisors are already fiduciaries, and a clearer distinction needs to be made that securities salespeople are not held to the same standard. Little regulation is needed, just clarification.