Subject: S7-32-10: Webform Comments from Free and Fair Markets Advocate
From: Anonymous
Affiliation:

Aug. 2, 2023

In my opinion, if this information is not already
disclosed, it is a violation of the SEC Investment Advisor Act of
1940. Let's say that Morgan Stanley and CO (the broker) is not
fully disclosing what's in their swaps, it can cause harm and
risk to the investment advisor clients on the Morgan Stanley Wealth
MGMT side. 

Wall St seems to believe that if they have two companies, The Charles
Schwab Corporation and Charles Schwab Wealth MGMT, or Citadel
Securities and Citadel Advisors that they can ignore the wider rules
related to the SEC Investment Advisor Act of 1940.

Let's not forget it requires Advisors to disclose risk to their
managed clients they charge fees and have fiduciary relationships
with. Why should they be allowed to hide whats in these swaps (values
in the hundreds of trillions) and not fully disclose these positions
to their clients? 

Is this not the other side putting their interest ahead of the
Investment Advisor subsidiary side of the business? The last I looked,
Charles Schwab has one ticker, Schwab trades under one Stock, so even
tho Schwab and CO and Schwab Wealth MGMT are two separate companies,
they are under the same umbrella. 

Then you have UBS Securities and UBS Wealth MGMT. If UBS is hiding
information in their Swaps shouldn’t the UBS wealth MGMT clients
know the truth? If their is major risk not being disclosed then is UBS
really putting their clients interest first? 

What are these big brokers trying to hide? Again, even if Citadel
Securitie is hiding positions in Swaps, shouldn’t Citadel Advisors
(the hedge fund, that operates on the side of a market maker) also
have the right to know? What is the risks are not being fully
disclosed to these clients?

In fact, how can the risks be disclosed when the large brokers and
securities firms are hiding trillions of dollars in investments and
risk. 

If you look through the entire industry they separate the investment
advisor and the broker, thinking it gives them the right to do what
ever they want and that they don't have to disclose it. Do you
really think this is fair to the clients who are being told that the
firm will always put their interest ahead of their own.

Why don’t you review the investment advisor act of 1940. It was
written by the SEC to stop conflicts of interest. It states that
Investment Advisors must put their clients interest ahead of their
own. Wall St has seperated the two sides and act like they can do what
every they want as its not technically the same company. This is a
Brokver/Dealer Vs Investment Advisor issue but in every instance, they
fall under the same major corporation. 

UBS Securities and UBS Wealth MGMT for example are the same ticker
stock symbol. The same with Charles Schwab and the same with Morgan
Stanley. It's the same through out the entire industry. 

Why should those large Broker/Dealer securities firms be allowed to
hide anything when a huge portion of their revenue comes from the
investment advisor side?