Subject: File No. S7-05-17
From: Donald M Homan, 3781074
Affiliation: ChFC

June 5, 2017

I see 3 major problems with the rule. As a Registered Representative and Investment Advisor Representative (with 30 years in the business) these rules reflect much of what I do now. I have a mature business with established clients. However, the problems:

First, A philsophical problem. Having an agency that does not have the authority to regulate an industry proclaim rules and then have a 3rd party (trial attorneys) enforce them is a perfect example of how poorly our government can operate.

Second, having trial attorneys enforce the rule will cause a wave of frivolous lawsuits. This will cause errors and omissions insurance to dramatically increase. I could retire but do not want to retire. But if these increases occur I will be forced to retire.

Third, my business is primarily with established clients. But I have always said I will work with anyone that wants to save money. That will change. If I can only be paid by fees a Roth IRA will not come close to paying for my time in terms of setting up an account. It also means it will be very difficult for a young representative to get started.