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

June 21, 2018 - Steve Busch

Subject: Fee Table
From: Steve Busch
June 21, 2018

I do not believe a fee table is warranted and expect it to cause more confusion than it solves.

A simpler approach would be to have investment management contracts lay out the fee structure (in table format if desired) so each client knows their specific fees and how they are calculated.  Our firm already does this so why confuse clients who only use some services or for services that only have one fee structure period?

As many larger firms, and perhaps some smaller ones as well, likely have many layers of fees, then maybe such firms should be required to use a table format.  Smaller firms, or firms with only straight forward AUM fee structures should be exempt from more burdensome regulations, but only if each client's fee structure is clearly defined in an investment management agreement signed by each client.

Regards,
Steve Busch, President
Everglades Resources, Inc.