Subject: File No. S7-07-18
From: Charles Vercellone, ChFC

June 28, 2018

I am all for a standard of care for the financial industry. We should, at all times, be working in the best interest of our clients. My concerns lie in 2 areas: restriction of the term Financial Planner or Financial Advisor, and non-securities sales people.

1) Financial Planner/Financial Advisor - I am seeing a push by some to restrict the term to those who carry the CFP designation. As a ChFC, I feel we comply to best interest standards and have gone through the work to earn a professional designation. The CFP (or ChFC for that matter) should not be a requirement to hold oneself out as a planner or advisor. I have no problem with the restriction being based on an affiliation with an RIA (as an IAR). I believe that distinction would best delineate the expectations of service.

2) Insurance only salespeople - while removing the ability of insurance only agents to hold themselves out as advisors or planners in the absence of an affiliation with an RIA, we still have the issues of many salespeople offering advice on securities accounts in the process of selling annuities. I realize insurance falls outside the realm of SEC oversight however, I see this as a the main stumbling block in raising the bar on professionalism.