July 2, 2018
While I understand the spirit behind the "Best Interest" rule, I believe the unintended consequences far outpace the potential benefits.
Many investors have worked hard to build retirement savings held in a brokerage accounts, such as SEP IRAs. Many such investors are long-term, buy and hold investors, with limited trading activity in a given year. As such, these investors pay minimal commissions in a brokerage account. Under the Best Interest rule, most of these accounts will be forced into a fee-based advisory model. Assuming an account balance of $1M, the annual management expenses could well be 10X what is currently paid in commissions. This is not tenable.
In addition, the younger and/or smaller investors would be hurt significantly by a fee-based only model, due to the limited investment dollars available to them, and the relative size of their total portfolio. Financial firms will be forced to set minimum fee standards to make the system work financially on their end. In so doing, the lower value accounts would be forced into a much more limited advisory and/or self-directed account status.
I urge the SEC to look beyond the popular rhetoric, and carefully weigh the full breadth of consequences to this important ruling.
Thank you for the opportunity to provide commentary.