August 7, 2018
RE:
• S7-07-18 for Regulation Best Interest
• S7-08-18 for Form CRS/Titles comments
• S7-09-18 for the RIA Harmonization proposals
Please make your rules so clear that your grandmother would understand the difference between and advisor and a broker. If she couldn't, then please don't assume others could. This is important to the many hardworking men and women that are trusting they will receive professional ADVICE on their life's savings.
Specifically, here are some concerns:
• 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.
• 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.
• 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.
• 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 (which my state, Tennessee, already has!).
Do what's right for the people. Hold a high standard for workers' hard earned money.
Thank you,
Jennifer