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

February 20, 2018 - Susan Burns

Subject: Request for Public Comment on Proposed Fee Table
From: Susan Burns
February 20, 2018


The emphasis on fees needs to be kept in proper context to the scope of services, experience, advice and value offered by various RIAs; not just comparing standalone fee schedules.

RIAs already provide fee and service information to consumers at the time of engagement, and on an annual basis, on Form ADV Part 2.

A standardized fee schedule within Form ADV Part 2 would offer a streamlined and simplified comparison without creating additional paperwork. It ensures that consumers receive information that is complete, accurate and timely, and eliminates the chance that Form ADV Part 2 and a separate fee schedule become out of sync.

Overall, a streamlined and simplified Form ADV Part 2 would be more accessible and understandable to the consumer, making comparisons easier.

A link at the RIA's website that provides a copy of their Form ADV Part 2's fee schedule or to FINRA's website achieves a similar result.

I think there is a greater risk to the consumer from websites that screen scrape or otherwise obtain and provide information on RIAs for profit. These websites may provide outdated, inaccurate and incomplete information that can be misleading. I would suggest that the Regulators consider holding these websites accountable to ensure that their information is accurate.