Subject: File Number S7-07-18
From: Richard Kahler

July 27, 2018

Honorable Jay Clayton

I am a financial planner from Rapid City South Dakota. Well a portion of my services are to offer investment advice, that is about 15% of the services I provide my clients, and the least labor intensive.

What is very different for me as to most “financial planners and “is that we do not sell any products whatsoever. Our focus his client centered, and advice. We charge a fee for service, just like an attorney or an accountant. All of my client facing staff have the CFP designation or a masters in financial planning.

We are technicians, not sales people. We have almost no conflicts of interest. If it’s in the best interest of our clients to invest in CD’s, we do that. It doesn’t affect our compensation. If we do have any conflicts of interest, the6 are clearly listed in our ADV.

The investments we do recommend are usually low cost, no load, index mutual finds. We spend a lot of time matching investment risk with the needs of our client. I guess 50% of what we do is educate clients on options and basics.

To equate a broker with a fee-only financial planner is like equating the game of rugby with the game of chess.

Best Regards,

Rick Kahler, MSFP, ChFC, CFP
A NAPFA Registered Financial Advisor