Jul. 24, 2018
The Honorable Jay Clayton
Chairman
United States Securities & Exchange Commission
Dear Chairman Clayton:
I am writing you in regard to the SEC's proposed rules on conduct standards for broker-dealers and investment advisors.
As a fee-only, registered investment advisor (RIA), I am a fiduciary level planner and advisor to my clients. The major focus of my services is financial planning, tax and wealth management. I do not sell products of any kind, nor am I licensed to do so. On the contrary, I am a professional advisor to my clients and am trained in finance and taxation, and am a Certified Financial Planner professional, and an Enrolled Agent licensed by the Treasury Department to represent taxpayers before the IRS.
As an RIA, I render fiduciary advice in intimate relationships of two; brokers can only offer incidental advice in sales relationships of three. I minimize conflicts of interest by only receiving compensation from client fees. Accordingly, I do not accept commissions or other third-party payments in connection with my recommendations. The fees and the underlying investment costs clients pay are set forth in advance and are transparent and clear. There is no confusion: My clients know what they've paid and what I've earned.
If I have any material conflicts, they are clearly listed and disclosed on my Firm's form ADV.
I hope this message helps you better understand the kind of professional a fee-only RIA is. If you require any further clarification, please feel free to contact me directly.
Sincerely,
William Cuthbertson, MBA, EA, CFP®
Fiscalis Advisory, Inc.