July 24, 2018

The Honorable Jay Clayton
Chairman,
United States Securities & Exchange Commission

Chairman Clayton:

Thank you for your service to our country and industry. I agree increasing investor and business accessibility to capital markets and decreasing regulation is the best direction. I believe clear communication and concise terminology are essential to protect the public and our country’s best interests, but currently, there are too many overlapping terms creating confusion.

For maximum clarity, I think we need two distinct definitions for investment advisors based on their underlying allegiance, compensation methods, and intended expertise. One likely titled an “Advisor” and the other likely titled a “Broker”.

Advisor format
Broker format

• Always a fiduciary
• Sometimes a fiduciary
• Allegiance ONLY to clients
• Allegiance to clients and employers or even third parties
• Compensated only by client
• May be compensated by third parties
• Ongoing compensation for continued oversight
• Transactional compensation without continued oversight
• Emphasis on holistic life planning
• Emphasis on investment or product design/sales
• Perhaps "Advisor" is most accurate definition
• Perhaps "Broker" is most accurate definition

Thanks again for your service and please let me know if I can be one to you.

My best,
Adam J. Leavitt, CFP®