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

June 21, 2018 - Kevin M. O’Brien

Subject: Fee Table comment
From: Kevin M. O’Brien
June 21, 2018

1. I think the fee tale will create better transparency and reduce the public’s confusion over fees.
2. I think there should be a separate header for Third-Party Asset Mngmt. Fees for TAMPS’ fees., which are usually significant
3. A separate table for one-off, flat-fee or hourly service fees, that are optional, would reduce confusion about what’s covered for AUM fees
4. Yes, they should be disclosed, and it could be done by my answer to #2
5. No, custodial fees are disclosed to the client by the custodian, and should remain so
6. I don’t think a Total Fee is appropriate, because some clients may receive other one-off services one year and not another
7. Services ancillary to AUM fees should be disclosed under the Services header
8. I think the disclosure of a fee table would create minimal work for most firms

KEVIN M. O'BRIEN, CFP, AIF, CAP
PEAK FINANCIAL SERVICES, INC.