November 9, 2018
Additional Comments attached.
During our meetings with various SEC staff regarding proposed title restrictions when using the term Adviser or Advisor, The Investments Wealth Institute was asked if it could provide draft language exempting individuals holding a legitimate, professional designation who otherwise did not meet the conditions of the proposed rule. Attached please find a redlined version with such proposed language.
We would be happy to address any questions regarding the attached draft. I can be reached at [redacted], or you may also contact our consultant, Duane Thompson, on this matter, at [redacted].
Thank you again for considering our concerns, and The Investments Wealth Institute offers whatever additional assistance that Commission may need or want.
Sincerely,
Robert E. Frankel, Esq.