April 7, 2014
SEC
I have read your proposed "new rules" regarding Regulatory Notice to Clients when a representative is changing Firms. While I am sure your motives are in the right place, I find your proposals over reaching, potentially damaging to the advisor - client relationship, and in some instances, impossible to avoid a legal "catch 22" scenario with previous contracts and agreements.
The Financial Services Institute has drafted proposed changes that I feel more adequately get to the heart of what a client needs for proper disclosure, yet does not over reach and cause potential legal harm to representatives or create conflicts with clients. It gives the client what he/she requires to make an intelligent decision and adequately informs what the client should know.
Please reconsider your proposal to be in line with what the FSI is proposing.
Thank you.
David L. Darner
Investment Advisor Representative
RDA Financial Network