July 31, 2018
Specifically, the primary points that concern me are:
1. 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
2. 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
3. Allowing 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
4. A potential new requirement that would require independent RIAs to have national continuing education requirements (separate from your CFP CE requirements, though hopefully cross-qualifying for both), and potential capital requirements in order to start or maintain an RIA