Request for Public Comment on Proposed Amendments to Investment Adviser Disclosure Regulations

April 3, 2019

Executive Summary

  • The Massachusetts Securities Division (“Division”) requests public comments on proposed amendments to existing regulations related to disclosure obligations of investment advisers who are registered in Massachusetts. Specifically, the Division proposes amendments that would:
    1. Require investment advisers registered in Massachusetts to provide clients and prospective clients with a table of fees for services provided by the investment adviser (“Fee Table”); and
    2. Revise paragraphs (a) and (d) of the existing regulations to remove redundancy and potential ambiguity in those paragraphs as currently drafted.
  • The purpose of the Fee Table is to increase transparency of advisory fees and costs, aid comprehension of advisory fees and costs, and enable investors to make more informed decisions when choosing their investment advisers. The Fee Table will achieve this goal by distilling the information about fees and services from the investment adviser's Brochure into a simple, digestible format that will enable side-by-side comparison of investment advisers and facilitate more informed questions and conversations about services and fees.
  • The Fee Table will be a one-page, stand-alone document based on information that is already in each investment adviser's Form ADV Part 2A. Updates and delivery of the Fee Table will be done consistently with the existing requirements for Form ADV.

Additional details about the proposed amendments, including background on the development of the Fee Table, can be accessed by opening the PDF attachment linked below.

Request for Public Comment (PDF)
Regulation, as amended (redline) (PDF)
Regulation, as amended (clean) (PDF)
Fee Table and Instructions (PDF)
Fillable Fee Table (DOCX)
Initial Small Business Impact Statement (PDF)

Request for Public Comment

The Division should receive written comments on the proposed amended regulations no later than Friday, May 3, 2019 at 5:00 p.m.   

We will post comments on the Massachusetts Securities Division website and comments are subject to public records laws. We do not edit personal identifying information from submissions; submit only information that you wish to make available publicly.

Submission via Mail

Please mail any comments on the proposed amendments to:

Office of the Secretary of the Commonwealth
Attn: Proposed Regulations – Fee Table
Massachusetts Securities Division
One Ashburton Place, Room 1701
Boston, MA 02108

Submission via Facsimile

Faxed comments may be sent to 617-248-0177. Comments sent via facsimile should include a cover sheet to the attention of “Proposed Regulations.”

Submission via Email

Email comments or submissions of scanned comment letters attached to an email may be submitted to

Submit a Comment


If you have questions about either of the proposed amendments, you may contact Carol Anne Foehl, Esq. or Dylan White, Esq. at 617-727-3548.

Public Hearing

A public hearing on these proposed changes will be held at 10:00 a.m. on Thursday, May 2, 2019 at One Ashburton Place, 17th Floor, Boston, MA 02108.

Interested parties will be afforded an opportunity to orally present data, views, and arguments relative to the proposed action. Written presentations may be made at the hearing or submitted at any time prior to the close of business on Friday, May 3, 2019 to the Massachusetts Securities Division via mail, facsimile, or email, as provided above.


Public Comments

May 3, 2019 - Brad Williams

May 3, 2019 - Financial Planning Association (PDF)

May 3, 2019 - Jay Lebed

May 3, 2019 - Paul Truesdell

May 2, 2019 - Institute for the Fiduciary Standard (PDF)

May 1, 2019 - Dustin Latham

May 1, 2019 - Douglas Beck

April 30, 2019 - John Kirby

April 30, 2019 - Chris Grande

April 30, 2019 - David H. McLaughlin

April 30, 2019 - Eric Bright

April 30, 2019 - Jeremy Bohne

April 30, 2019 -

April 30, 2019 - Peggy McGillin

April 30, 2019 - Abraham McAllister

April 20, 2019 - Kieran Rooney

April 17, 2019 - William D’Annibale

April 17, 2019 - Bill Schretter

April 11, 2019 - John Boyle

April 9, 2019 - Jim Beaulieu

April 4, 2019 - Charlo Maurer

April 4, 2019 - Herbert Shanzer

April 4, 2019 -

April 4, 2019 - Peter Canniff

April 3, 2019 - Abe Ringer

April 3, 2019 - Carlos Rodriguez

April 3, 2019 - Daniel J. Traub

April 3, 2019 - Harold Hallstein

April 3, 2019 - Michael R. Lopes

April 3, 2019 - Patrick Sheppard

April 3, 2019 - Peter C. Wernau