Subject: File No. S7-09-18
From: Daniel Wrenne, CFP, CLU, ChFC

July 31, 2018

I was a registered rep for a large insurance broker-dealer for 9 years. And have been running my RIA for 4 years now.

I believe the new proposal requiring independent RIA's to have national continuing education requirements and potential capital requirements is a step in the wrong direction. It further increases barriers to entry and causes greater confusion in the overall industry continuing education requirement.

I believe a better step would be to increase continuing education requirements for RIA's through already existing programs. Maybe all RIA's could be required to operate under CFP CE standards or even operate as CFPs. The CFP is a very established and well respected professional standard for providers of financial advice. Lots of great work has already been done to advance these professional standards. Why not build on the great work that's already been done instead of reinventing the wheel.