Subject: Comment on Proposed Rules
From: PJ Wallin
Affiliation:

Jul. 31, 2018

As a fee-only, fiduciary, independent registered investment advisory firm owner, I would like to comment on the following:

• S7-07-18 for Regulation Best Interest
• S7-08-18 for Form CRS/Titles comments
• S7-09-18 for the RIA Harmonization proposals

We strongly believe there needs to be a strict delineation between those who sell products (i.e. brokers) and those who are consultants providing advice as a service (financial advisors).

We believe the current rules are watering down and blurring the lines between this very important distinction.

I've worked in several firms before owning my own firm. I believe allowing brokers to use the title financial advisor is confusing and the lines are confused as to whether a person has a true fiduciary responsiblity to their clients.

Please re-consider your "Regulation Best Interest" standard as it would be a negative to the general public.

Please reconsider the Form CRS/Titles that allows confusing disclosures and misrepresentations of titles to folks who are clearly selling products and not working in a fiduciary capacity.

Please reconsider the RIA CE requirements. As a CPA and CFP, I already have enough CE requirements to keep annually; Additional RIA CE requirements should only be required if advisors don't have CFP/CPA/CFA designations (one of them).....as they require CE anyways.

Thanks for your consideration,

PJ Wallin

PJ Wallin CPA/PFS, CFP®