The following Letter Type H, or variations thereof, was submitted by individuals or entities.

Letter Type H:

The Honorable Jay Clayton, Chairman
United States Securities & Exchange Commission
SEC Headquarters
100 F Street, NE
Washington, DC 20549

Dear Chairman Clayton,

I have been working as an RIA on behalf of my clients for over three years and I appreciate having the opportunity to comment on the proposed rule.

My firm provides comprehensive financial advice to its clients. We manage our clients' investments, help plan for retirement, make sure they are properly insured, and ensure their estate plans meet our clients' goals. Our major focus of service is holistic financial planning and managing clients' life savings and helping them make optimal decisions is not only rewarding but also a great responsibility Ido not take lightly. For that reason, I think it is imperative I look at each question as objectively and professionally as demanded of fiduciaries. I strive to always put my client's best interest first. Our firm has minimized our conflicts. Those material conflicts that remain are described and explained as well as possible, so my client really understands what it means.

We only accept compensation that is paid directly to us by our clients. We also do our best to ensure fees and underlying expenses are competitive, transparent, and justifiable. We do not sell any products and we have freedom in selecting and managing investments. We do not sell insurance or proprietary products or engage in principal trading. Our advisors are not trained in sales but have CFP® and CFA designations. We encourage our employees to seek continuing education to stay up to date and provide the best advice possible.

Brokers are in a very different position. Abroker's business model involves a third party (the investment company) in addition to the client and the broker. As an RIA, i render fiduciary advice in intimate relationship of two; brokerage can only offer incidental advice in sales relationship with third parties. For this reason, the broker has natural and unavoidable conflicts of interest. For this reason, Irespectfully ask that you consider these embedded differences when comparinq brokers and RIAs.

We have helped a number of clients over the years who have come from brokers. Many of these clients came to us with well-designed portfolios, but most of these clients were unaware of the expenses associated with their portfolio. Some clients thought they were receiving free advice from their broker. We have helped many clients unwind over-priced annuities and navigate diversifying portfolios while avoiding onerous deferred sales charges. Unfortunately I cannot think of a reason why clients held these investments other than (1) incompetence, or (2) misaligned interests between the broker and my client. We also have clients who come to us after leaving another RIA. These clients' portfolios are invariably as well as diversified, tax-efficient and lower cost than the portfolios coming from brokers. Our experience indicates brokers have a significantly different service model and set of incentives from RIAs.

I minimize conflicts by only receiving compensation from client fees; Ido not accept commissions or other third-party payments in connection with my recommendations. If we have any material conflicts, they are clearly listed on our ADV.

I appreciate you taking the time to review my comments and experiences on the proposed rule.

Sincerely,

http://www.sec.gov/comments/s7-07-18/s70718-typeh.htm