Subject: File No. S7-07-18
From: Elizabeth Copley, Esquire
Affiliation: FINRA Arbitrator

April 19, 2018

As a Securities Arbitrator for over 20 years, I am very familiar with numerous broker dealer practices/procedures. Most, if not all, have established guidelines for handling trust accounts. Financial Consultants are likewise well informed regarding these. Considering/coding Retirement accounts ( IRA'S, 401k's etc.) Trust Accounts would seem to be logically consistent and would require no additional training for Financial Consultants. Thus, a smooth transition for all concerned with investors receiving highest consistent protection.