Preliminary Request for Public Comment on Proposed Fee Table for State-Registered Investment Advisers

February 7, 2018 - Ted Wolfstich

Subject: Fee Table
From: Ted Wolfstich
February 7, 2018

Good morning,

I just received your fee table Summary piece and had a couple comments.  In general, I think it is a good idea, the more transparency in the business the better.  One concern however is putting down the services part, specifically financial planning.  As you are aware there are years where an advisor might do a lot of planning and years where there is not much work to do for someone.  If I was to put down that I do both investment management and financial planning and for a period of time did no planning because none was needed is that some how a liability?  

The next question would be do you need to put down the fees of the mutual funds/exchange traded funds that are embedded or is it just if you were to use a separate account manager?  I would think if you needed to put down the embedded costs it could be quite onerous if you changed funds etc.

Ted Wolfstich CFP®
Wolfstich Capital