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

July 16, 2018 - Dennis Butler

Subject: Fee Table comment
From: Dennis Butler
July 16, 2018

Proposed Fee Table

Since much of the data that would appear in your proposed table can be found elsewhere in the ADV, this requirement would be duplicative and represent a paperwork burden, particularly for small firms.

However, I do believe it would be very useful for clients to have access to contextual data with respect to fees, so they can compare their experience with the range of fees charged in the industry for various services. Since the Division has access to this material, posting it on your own website would provide an ideal go-to resource for investors seeking this information.


Dennis Butler
Centre Street Cambridge Corporation
Private Investment Counsel