Jul. 31, 2018
Specifically, the primary points that concern me are the following:
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. This undermines the trust of capital markets and the end client . This is very misleading to the consumer.
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. Another example of misleading the end consumer.
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. These need to clearly be defined if not another example of misleading the consumer.
A potential new requirement that would require independent RIAs to have national continuing education requirements (separate from my CFP CE requirements, though hopefully cross-qualifying for both!), and potential capital requirements in order to start or maintain an RIA. This undermines the creativity and free capital markets to drive costs down for the end consumer. More regulations in business formation is bad business in any industry.