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

February 7, 2018 - Richard J. Carlesco Jr.

Subject: Fee Table
From: Richard J. Carlesco Jr.
February 7, 2018

I am against such a rigid rule.
However I can see your point, in the real world we do have a fee schedule, but sometimes we will negotiate a fee for some clients at the registered rep level. We will waive fees in most case for friends or families. What would make more sense would be to post a maximum fee schedule. So clients can make sure they are not being over charged. Our compliance department reviews fees charged to clients at point of sale and on a monthly basis.

PS. Fees are always disclosed on client statements. What is not disclosed very well are trading fees, by advisors that have control of trading costs from their clearing firm. They could be marking up or down trades. So that the real trade costs are hidden. Mutual Funds have been doing this for years. If you would like to call and discuss further I would love to help.

Richard J. Carlesco Jr. LUTCF
IBN Financial Services, Inc.