Secretary Galvin Proposes New Regulations Related to Investment Adviser Representative Registration

Submitted Comments

Monday, March 18, 2013


From: Christopher Grande
Sent: Monday, March 18, 2013 4:58 PM


CORI background checks are fine. Would not be a challenge to incorporate them into the process. An easy way to submit (secure fax/email/etc) would make the process a snap.

Thanks for sharing the proposals.

Chris Grande



Konstantin Litovsky
Monday, March 18, 2013 5:49 PM

1.What are the potential effects of requiring a CORI Acknowledgement Form as part of the registration process?

What is the purpose for this? We are already finger-printed, so what's the use of this for small firms with one or more principals and no other employees? As it is, the paperwork is burdensome for small firms such as ours. Any more paperwork is certainly not appreciated. And this is really a total waste of time for us as it accomplishes no purpose whatsoever.

2.What are the potential costs to an applicant or his or her firm (including the added time needed to complete an application) should the CORI Acknowledgement Form be made part of the application?

The cost is more than we are currently interested in paying.

3.Should the Division specifically designate methods of filing CORI Acknowledgement Forms?

This may be something that can be asked of bigger firms with say 10 or more employees. There is absolutely no need for this for smaller firms. Thus, they should be excluded from this requirement.

4.The completed CORI Acknowledgement Form contains personal information including the applicant’s name, partial social security number, and date of birth. What are the potential effects of this regulation change as it relates to
Massachusetts privacy laws (including, but not limited to, M.G.L. Ch. 93H)?

The State does not have a good record for safeguarding privacy of IARs, so privacy is definitely a big concern.

Thank you,

Konstantin Litovsky, Principal
Litovsky Asset Management
Newton, MA



From: "J. Christopher Boyd, CFP®"
Sent: Monday, March 18, 2013 6:05 PM

The addition of a CORI component to the IAR application seems a reasonable addition to the process. Although I am uncertain whether notarization is necessary, I favor this addition in an effort to protect our clients from those who may have unscrupulous intentions. If it exists, I would favor a national version of the CORI check that has a scope beyond criminal activity in Massachusetts. We are uncertain as to how to complete such a criminal background check, but would like to do that as a part of our advisor hiring practice anyway.

Thank you for your interest in advisor input in this matter.


Chris Boyd

J. Christopher Boyd, CFP®, CASL®
Chief Investment Officer & Managing Member
Asset Management Resources, LLC
1060 Falmouth Road, Suite B-2
Hyannis, MA 02601



From: Peggy McGillin,CFP(R)
Sent: Monday, March 18, 2013 6:13 PM

I would have no problem with this. I think it will help the profession and prevent criminals from ruining the industry’s reputation. I think this helps the RIAs and investors.

Thank you for asking,

Best regards,

Peggy McGillin, CFP®

Journey Financial Planners

Understanding Your PrioritiesTM

747 Main Street
Suite 120
Concord, MA 01742


Tuesday, March 19, 2013


From: Dennis Conlon
Sent: Tuesday, March 19, 2013 6:46 AM

sounds reasonable. I'd be happy to comply.



From: Matie Krebs
Sent: Tuesday, March 19, 2013 8:03 AM

We don’t have any IARs in Massachusetts.

Matie Krebs, CCO
Advanced Investment Partners, LLC
100 Main Street, #301
Safety Harbor, FL 34695


Tuesday, March 26, 2013


From: Neil Collins
Sent: Tuesday, March 26, 2013 1:45 PM
Subject: dissent

To whom it may concern:

In regards to the proposal to include a CORI form in the IAR registration process, I would like to voice my dissent. The process as it stands currently works fine for our firm and any additional form would require more time and complexity for which we see no benefit. All proposals for new regulation are done with good intentions however they have consequences. I can't help think of how an applicant would be treated with Marijuana offenses on his record. Would that preclude him from registration? What would or wouldn't preclude or delay registration and employment? Marijuana has been decriminalized and now is going to be legal for medicinal use. I am more fearful of over regulation and the consequences to small business than I am of what someone had done in the past. Principals of RIA firms should be the gatekeepers of their Reps behavior and ethics, not a digital depository.

I consider this form to be a slippery slope toward more regulation for little or no benefit undermining the democratic business model that so many of us rely on to make a living and compete against much larger rivals.

Neil R. Collins
managing member
Marblehead Capital, LLC
100 Cummings Center Suite 223F
Beverly, MA 01915

Saturday, March 30, 2013


Peter Canniff Comment Letter Dated 3.30.13 (PDF)

Tuesday, May 14, 2013


SIFMA Comment Letter Dated 5.14.13 (PDF)


Thursday, May 15, 2013


Commonwealth Financial Network Comment Letter Dated 5.15.13 (PDF)


Financial Services Institute Comment Letter Dated 5.15.13 (PDF)


Market Council Comment Letter Dated 5.15.13 (PDF)