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

June 24, 2018 - William Harris

Subject: Fee Table comment
From: William Harris
June 24, 2018

To Whom It May Concern,

As the principal for a Massachusetts' state registered investment advisory firm, I share the Division’s belief that increased transparency would allow consumers to better compare advisor services and fees and be beneficial to the industry. However, I believe the fee table, as proposed, would not accurately reflect the range of services and business models offered by financial planners and may create additional confusion. 

I am also concerned that that the proposed fee table would only apply to Massachusetts' registered investment advisors. As a result, additional burdens and costs will be borne by my firm and other smaller state-registered advisors vis-à-vis larger SEC-registered advisors, broker-dealers and insurance agents. Ultimately, making Massachusetts state registered firms less competitive. Consumers will be unable to compare fees and services of Massachusetts-registered advisors to non-Massachusetts-registered advisors, thus limiting the effectiveness of the proposed rule.  

Consumers benefit via fair competition. Consumers, state registered firms and the Division all suffer when Massachusetts state registered firm gradually close down because of undue regulatory burdens.

Sincerely,

William Harris, CFP®
WH Cornerstone Investments