August 6, 2018
Dear Chairman Clayton.
I am a financial planner and advisor to my clients. The major focus of my services is financial planning. I spend about 75% of my billable time providing advice and analysis to help clients with topics that exclude portfolio design and management (about 25%). Many of my clients are self-direct investors who seek my advice and analysis for portfolios they self-direct at Vanguard, Schwab, Fidelity or TD Ameritrade.
I have an MBA from the University of Chicago Booth School and worked a couple of decades in the corporate world before becoming a fee-only financial planner.
As an Investment Advisor Representative of a RIA firm that is fee-only, I render fiduciary advice; my compensation comes solely from fees paid by clients. My fee-model is hourly and project based fees.
Though based on my education (MBA and continuing), I emphasize low-cost index-based or factor investing; I may also advise clients to consider single premium annuities or other products to provide income in their post-earnings years. I don't sell those products; however, I may help clients obtain competitive quotes and analyze how the role they may play in their retirement projections.
Often the major portion of clients investment portfolios are in their employer-based retirement plans; after analysis of the investment choices available including the costs and historical performance, the distribution options available to the employer or his or her beneficiaries at retirement, I often recommend that retirees continue to invest through their employer retirement plans.
The fees and underlying investment costs of any investments I recommend are transparent. When clients want to delegate investment management, I help them find potential investment managers, obtain proposals and then analysis the costs and proposed strategies.
I do not sell insurance or engage in any proprietary training.
Sadly, I have met many prospective clients whose financial resources were degraded by owning accounts or products that they did not understand with high investment expenses often with no discernible or stated strategy that reflected their unique financial profiles, resources or goals.
The proposed SEC rule seems to reflect a view that brokers (investment salespersons) and advisor are virtually the same. This does not seem to be consistent with The Investment Advisers Act of 1940.
The Best Interest Standard as outlined does not address the issues faced by consumers when they encounter sophisticated marketing techniques and complex issues. The title itself is misleading and confusing.
I appreciate your consideration and encourage the commission to reconsider the Proposed Regulation Best Interest Rule.
Leisa Brown Aiken CFP®
dba VEO Financial Counsel