Jul. 31, 2018
To Whom It May Concern:
I am writing to comment on the following:
I work with fee-only advisors across the country. I see the work they do and hear the horror stories they have of clients formerly served by non-fiduciary financial advisors. I beg of you to work to make a clear delineation between the commissioned side of the business and a true fee-only fiduciary.
Specifically, the primary points that concern me are: • The proposed “Regulation Best Interest” standard that would allow broker-dealers to say they act in the “best interests” of their clients, without actually being subject to a full fiduciary duty. The public does not understand what a part time fiduciary is.
• Form CRS disclosure that is supposed to explain the relationship between advisors and brokers, but uses confusing language that blurs (instead of highlighting) the distinction between who can and should legally give advice, versus who is compensated for the sale of a product. We should be making it easier - not harder - to determine how clients are paying for services and how their advisors are getting compensated.
• Hybrid broker-dealers should be required to state that they are selling, not just advising. Allowing them to claim to be “financial advisors” without any requirement to disclose when start selling is clouding the message.
Please work to further protect the consumer, not advisors who do not work in their clients best interest.
Best regards,
Arlene Moss