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

June 22, 2018 - Therese R Nicklas

Subject: Fee Table comment
From: Therese R Nicklas
June 22, 2018

I reviewed the proposed regulations regarding the requirement for MA state registered RIA’s to create a fee table to be given to clients.

I appreciate the intention of providing fee transparency to clients. In my opinion, simplicity leads to clarity. I am concerned that the regulation as written will cause confusion on the part of the advisor and consumer. My additional concern is the possibility that financial advisors will become a commodity where the focus will be on cost instead of the value of advice and importance of a trusted advisor/client relationship. I appreciate the point made by the Financial Planner’s Association regarding singling out MA state registered RIAs. If this is the direction of the MA Securities Division, the same standard should apply to SEC registered firms, broker/dealers and commissioned insurance sales representatives. Rather than being redundant, I support the opinions of the Financial Planning Association and Michael Kitces. I believe they stated their case clearly. My opinion and recommendations are the same as those of the Financial Planners Association and Michael Kitces.

Sincerely,
Therese R. Nicklas, CFP®
Therese R. Nicklas, CFP®, CMC®
Certified Money Coach