Subject: File No. S7-21-19
From: Bob Kargenian, CMT
Affiliation: President, TABR Capital Management, LLC

January 6, 2020

I hope my comments can still be included but it looks like the deadline was January 4?

As a practicing RIA who is a fee-only fiduciary, I believe the proposed rule to allow testimonials for RIA firms should not be allowed.

According to published research, up to 40% or higher of YELP reviews of consumer providers are fake. Social media companies are failing to stop manipulated activity, according to a report by NATO-affiliated researchers.

I think this would open up another can of worms for the SEC, in determining how to police the validity of such testimonials. Our business, and that of thousands of other RIA firms, is doing just fine under the prohibition of testimonials.

Please leave well enough alone, and not increase the workload of SEC examiners.

Thank you,
Bob

Bob Kargenian, CMT
President
TABR Capital Management, LLC
500 N. State College Blvd, STE 1320
Orange, CA 92868
www.tabr.net