Solicitation of Comments on Proposed Fiduciary Conduct Standard for Broker-Dealers, Agents, Investment Advisers, and Investment Adviser Representatives

Subject: NO MA Fiduciary Rule - BAD FOR CONSUMERS
From: Matthew Berard

Good Morning Secretary Galvin-

My name is Matthew Berard, and I am a member of the local Massachusetts chapter of the National Association of Insurance and Financial Advisors (NAIFA)*. NAIFA –MA has over 470 licensed insurance and financial planners doing business with your constituents in the Commonwealth of Massachusetts. In addition to being a NAIFA member, I am also the Insurance Brokerage Director & Disability Income Specialist for an insurance and financial planning firm in Needham, MA. I have been in the insurance planning business, specializing in disability insurance for 22 years and have insured over 10,000 clients and work with over 400 insurance & financial advisors.

NAIFA Massachusetts and NAIFA support a nationwide, uniform "best interest" standard of care for securities recommendations and transactions. The SEC's recently adopted Regulation Best Interest (Reg BI) establishes a workable national best interest standard of conduct that provides a significant strengthening of the standard of care for broker-dealers and their representatives while also preserving the existing business models (advisory and brokerage) that consumers want and need. In addition, the National Association of Insurance Commissioners is in the final stages of amending its model regulation on annuity recommendations and sales to include a best interest standard that aligns well with the SEC's Reg BI. These regulatory actions by the SEC and the NAIC will accomplish both regulator's and industry's goal of protecting our clients while also preserving a business model that is appropriate for agents and advisors.

The current proposal from you office, by contrast, is flawed. At a high level, some of the key concerns with your proposal are as follows:

• The proposal increases consumers' costs while decreasing consumer choice.
• The proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.
• The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
• Since most fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
• The proposal may also limit consumer choices on annuity and life insurance products. The additional costs associated with complying with this regulation may ultimately reduce the performance of these products.
• The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

NAIFA has always been most concerned about giving our clients the best service and advice possible given each of our clients' particular situations. As we all know there is no one strategy that works for every client and we support regulation that allows our clients to have a choice of both strategy and the method of receiving advice and accessing products that best fits their own needs.

*The National Association of Insurance and Financial Advisors (NAIFA) Massachusetts over 470 members statewide who are licensed insurance agents and financial advisors who focus their practices on one or more of the following: long term care insurance, disability insurance, life insurance and annuities, health insurance and employee benefits, multiline, and financial advising and investments.

Matthew P. Berard
Insurance Brokerage Director & Disability Income Specialist

Subject: Fee Table comment
From: Martin Connolly

This proposed legislation will increase the cost to the client as compliance costs will increase over time.  This will also potentially move all brokers and agents into fee based planning, which will eliminate commission based services for everyone not able to pay $2-5,000 for a basic financial plan.  This legislation does more harm than good to the client, who is looking forward financial advice. 

Best,

Martin Connolly, JD | Director | Financial Advisor

Subject: MA FIDUCIARY RULE is BAD for Consumers
From: Martin Lowenthal

Good Morning Secretary Galvin-

My name is Martin Lowenthal, and I am a financial and insurance advisor with a financial & insurance planning firm in Needham, MA. I have been in the financial and insurance planning business, specializing in insurance and investment planning for years and have helped many clients within the Commonwealth of MA plan for their secure financial future.

I support a nationwide, uniform "best interest" standard of care for securities recommendations and transactions. The SEC's recently adopted Regulation Best Interest (Reg BI) establishes a workable national best interest standard of conduct that provides a significant strengthening of the standard of care for broker-dealers and their representatives while also preserving the existing business models (advisory and brokerage) that consumers want and need. In addition, the National Association of Insurance Commissioners is in the final stages of amending its model regulation on annuity recommendations and sales to include a best interest standard that aligns well with the SEC's Reg BI. These regulatory actions by the SEC and the NAIC will accomplish both regulator's and industry's goal of protecting our clients while also preserving a business model that is appropriate for agents and advisors.

The current proposal from your office, by contrast, is flawed. At a high level, some of the key concerns with your proposal are as follows:

• The proposal increases consumers' costs while decreasing consumer choice.
• The proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.
• The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
• Since most fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
• The proposal may also limit consumer choices on annuity and life insurance products. The additional costs associated with complying with this regulation may ultimately reduce the performance of these products.
• The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

NAIFA has always been most concerned about giving our clients the best service and advice possible given each of our clients' particular situations. As we all know there is no one strategy that works for every client and we support regulation that allows our clients to have a choice of both strategy and the method of receiving advice and accessing products that best fits their own needs.

*The National Association of Insurance and Financial Advisors (NAIFA) Massachusetts over 470 members statewide who are licensed insurance agents and financial advisors who focus their practices on one or more of the following: long term care insurance, disability insurance, life insurance and annuities, health insurance and employee benefits, multiline, and financial advising and investments.

Subject: MA FIDUCIARY RULE is BAD for Consumers
From: Brian McGrath

Good Morning Secretary Galvin-

My name is Brian McGrath, and I am a financial and insurance advisor with a financial & insurance planning firm in Needham, MA. I have been in the financial and insurance planning business, specializing in insurance and investment planning for years and have helped many clients within the Commonwealth of MA plan for their secure financial future.

I support a nationwide, uniform "best interest" standard of care for securities recommendations and transactions. The SEC's recently adopted Regulation Best Interest (Reg BI) establishes a workable national best interest standard of conduct that provides a significant strengthening of the standard of care for broker-dealers and their representatives while also preserving the existing business models (advisory and brokerage) that consumers want and need. In addition, the National Association of Insurance Commissioners is in the final stages of amending its model regulation on annuity recommendations and sales to include a best interest standard that aligns well with the SEC's Reg BI. These regulatory actions by the SEC and the NAIC will accomplish both regulator's and industry's goal of protecting our clients while also preserving a business model that is appropriate for agents and advisors.

The current proposal from your office, by contrast, is flawed. At a high level, some of the key concerns with your proposal are as follows:
· The proposal increases consumers' costs while decreasing consumer choice.
· The proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.
· The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
· Since most fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the
advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
· The proposal may also limit consumer choices on annuity and life insurance products. The additional costs associated with complying with this regulation may ultimately reduce the performance of these products.
· The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

NAIFA has always been most concerned about giving our clients the best service and advice possible given each of our clients' particular situations. As we all know there is no one strategy that works for every client and we support regulation that allows our clients to have a choice of both strategy and the method of receiving advice and accessing products that best fits their own needs.

*The National Association of Insurance and Financial Advisors (NAIFA) Massachusetts over 470 members statewide who are licensed insurance agents and financial advisors who focus their practices on one or more of the following: long term care insurance, disability insurance, life insurance and annuities, health insurance and employee benefits, multiline, and financial advising and investments

Sincerely,

Brian
--
Brian P. McGrath
Financial Advisor

Subject: MA FIDUCIARY RULE is BAD for Consumers
From: Peter Klay

Good Afternoon Secretary Galvin-

My name is Peter Klay, and I am a financial and insurance advisor with a financial & insurance planning firm in Needham, MA. I have been in the financial and insurance planning business, specializing in insurance and investment planning for years and have helped many clients within the Commonwealth of MA plan for their secure financial future.

I support a nationwide, uniform "best interest" standard of care for securities recommendations and transactions. The SEC's recently adopted Regulation Best Interest (Reg BI) establishes a workable national best interest standard of conduct that provides a significant strengthening of the standard of care for broker-dealers and their representatives while also preserving the existing business models (advisory and brokerage) that consumers want and need. In addition, the National Association of Insurance Commissioners is in the final stages of amending its model regulation on annuity recommendations and sales to include a best interest standard that aligns well with the SEC's Reg BI. These regulatory actions by the SEC and the NAIC will accomplish both regulator's and industry's goal of protecting our clients while also preserving a business model that is appropriate for agents and advisors.

The current proposal from your office, by contrast, is flawed. At a high level, some of the key concerns with your proposal are as follows:

• The proposal increases consumers' costs while decreasing consumer choice.
• The proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.
• The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
• Since most fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
• The proposal may also limit consumer choices on annuity and life insurance products. The additional costs associated with complying with this regulation may ultimately reduce the performance of these products.
• The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

NAIFA has always been most concerned about giving our clients the best service and advice possible given each of our clients' particular situations. As we all know there is no one strategy that works for every client and we support regulation that allows our clients to have a choice of both strategy and the method of receiving advice and accessing products that best fits their own needs.

*The National Association of Insurance and Financial Advisors (NAIFA) Massachusetts over 470 members statewide who are licensed insurance agents and financial advisors who focus their practices on one or more of the following: long term care insurance, disability insurance, life insurance and annuities, health insurance and employee benefits, multiline, and financial advising and investments.
Thank you,

Peter A. Klay
Managing Director
The Bullfinch Group

Subject: MA FIDUCIARY RULE is BAD for Consumers
From: Ari Stonehill

Good Morning Secretary Galvin-

My name is Ari Stonehill, and I am a member of the local Massachusetts chapter of the National Association of Insurance and Financial Advisors (NAIFA)*. NAIFA –MA has over 470 licensed insurance and financial planners doing business with your constituents in the Commonwealth of Massachusetts. In addition to being a NAIFA member, I am also a financial and insurance advisor (Registered Investment Advisor - RIA) with a financial & insurance planning firm in Needham, MA. I have been in the financial and insurance planning business, specializing in insurance and investment planning for over 23 years and have insured many clients within the Commonwealth of MA.

I support a nationwide, uniform "best interest" standard of care for securities recommendations and transactions. The SEC's recently adopted Regulation Best Interest (Reg BI) establishes a workable national best interest standard of conduct that provides a significant strengthening of the standard of care for broker-dealers and their representatives while also preserving the existing business models (advisory and brokerage) that consumers want and need. In addition, the National Association of Insurance Commissioners is in the final stages of amending its model regulation on annuity recommendations and sales to include a best interest standard that aligns well with the SEC's Reg BI. These regulatory actions by the SEC and the NAIC will accomplish both regulator's and industry's goal of protecting our clients while also preserving a business model that is appropriate for agents and advisors.

The current proposal from your office, by contrast, is flawed. At a high level, some of the key concerns with your proposal are as follows:
· The proposal increases consumers' costs while decreasing consumer choice.
· The proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.
· The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and
responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
· Since most fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
· The proposal may also limit consumer choices on annuity and life insurance products. The additional costs associated with complying with this regulation may ultimately reduce the performance of these products.
· The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

NAIFA has always been most concerned about giving our clients the best service and advice possible given each of our clients' particular situations. As we all know there is no one strategy that works for every client and we support regulation that allows our clients to have a choice of both strategy and the method of receiving advice and accessing products that best fits their own needs.

*The National Association of Insurance and Financial Advisors (NAIFA) Massachusetts over 470 members statewide who are licensed insurance agents and financial advisors who focus their practices on one or more of the following: long term care insurance, disability insurance, life insurance and annuities, health insurance and employee benefits, multiline, and financial advising and investments

Sincerely,

Ari Stonehill

Subject: MA FIDUCIARY RULE is BAD for Consumers
From: Boris Lokshin

Good Morning Secretary Galvin-

My name is Boris Lokshin, and I am a member of the local Massachusetts chapter of the National Association of Insurance and Financial Advisors (NAIFA)*. NAIFA –MA has over 470 licensed insurance and financial planners doing business with your constituents in the Commonwealth of Massachusetts. In addition to being a NAIFA member, I am also a financial and insurance advisor (Registered Investment Advisor - RIA) with a financial & insurance planning firm in Needham, MA. I have been in the financial and insurance planning business, specializing in insurance and investment planning for over 23 years and have insured many clients within the Commonwealth of MA.

I support a nationwide, uniform "best interest" standard of care for securities recommendations and transactions. The SEC's recently adopted Regulation Best Interest (Reg BI) establishes a workable national best interest standard of conduct that provides a significant strengthening of the standard of care for broker-dealers and their representatives while also preserving the existing business models (advisory and brokerage) that consumers want and need. In addition, the National Association of Insurance Commissioners is in the final stages of amending its model regulation on annuity recommendations and sales to include a best interest standard that aligns well with the SEC's Reg BI. These regulatory actions by the SEC and the NAIC will accomplish both regulator's and industry's goal of protecting our clients while also preserving a business model that is appropriate for agents and advisors.

The current proposal from your office, by contrast, is flawed. At a high level, some of the key concerns with your proposal are as follows:
· The proposal increases consumers' costs while decreasing consumer choice.
· The proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.
· The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and
responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
· Since most fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
· The proposal may also limit consumer choices on annuity and life insurance products. The additional costs associated with complying with this regulation may ultimately reduce the performance of these products.
· The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

NAIFA has always been most concerned about giving our clients the best service and advice possible given each of our clients' particular situations. As we all know there is no one strategy that works for every client and we support regulation that allows our clients to have a choice of both strategy and the method of receiving advice and accessing products that best fits their own needs.

*The National Association of Insurance and Financial Advisors (NAIFA) Massachusetts over 470 members statewide who are licensed insurance agents and financial advisors who focus their practices on one or more of the following: long term care insurance, disability insurance, life insurance and annuities, health insurance and employee benefits, multiline, and financial advising and investments

Sincerely,

Boris Lokshin

Subject: NO MA Fiduciary Rule - LESS CHOICE FOR CONSUMERS
From: Adam Sachs

Good Morning Secretary Galvin-

My name is Adam Sachs, and I am a member of the local Massachusetts chapter of the National Association of Insurance and Financial Advisors (NAIFA)*. NAIFA –MA has over 470 licensed insurance and financial planners doing business with your constituents in the Commonwealth of Massachusetts. In addition to being a NAIFA member, I am also a financial and insurance advisor (Registered Investment Advisor - RIA) with a financial & insurance planning firm in Needham, MA. I have been in the financial and insurance planning business, specializing in insurance and investment planning for over 23 years and have insured many clients within the Commonwealth of MA.

I support a nationwide, uniform "best interest" standard of care for securities recommendations and transactions. The SEC's recently adopted Regulation Best Interest (Reg BI) establishes a workable national best interest standard of conduct that provides a significant strengthening of the standard of care for broker-dealers and their representatives while also preserving the existing business models (advisory and brokerage) that consumers want and need. In addition, the National Association of Insurance Commissioners is in the final stages of amending its model regulation on annuity recommendations and sales to include a best interest standard that aligns well with the SEC's Reg BI. These regulatory actions by the SEC and the NAIC will accomplish both regulator's and industry's goal of protecting our clients while also preserving a business model that is appropriate for agents and advisors.

The current proposal from your office, by contrast, is flawed. At a high level, some of the key concerns with your proposal are as follows:
· The proposal increases consumers' costs while decreasing consumer choice.
· The proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.
· The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and
responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
· Since most fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
· The proposal may also limit consumer choices on annuity and life insurance products. The additional costs associated with complying with this regulation may ultimately reduce the performance of these products.
· The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

NAIFA has always been most concerned about giving our clients the best service and advice possible given each of our clients' particular situations. As we all know there is no one strategy that works for every client and we support regulation that allows our clients to have a choice of both strategy and the method of receiving advice and accessing products that best fits their own needs.

*The National Association of Insurance and Financial Advisors (NAIFA) Massachusetts over 470 members statewide who are licensed insurance agents and financial advisors who focus their practices on one or more of the following: long term care insurance, disability insurance, life insurance and annuities, health insurance and employee benefits, multiline, and financial advising and investments

Sincerely,

Adam Sachs

Subject: MA FIDUCIARY RULE is BAD for Consumers
From: Michael Elcock

Good Morning Secretary Galvin-

My name is Michael Elcock, and I am a member of the local Massachusetts chapter of the National Association of Insurance and Financial Advisors (NAIFA)*. NAIFA –MA has over 470 licensed insurance and financial planners doing business with your constituents in the Commonwealth of Massachusetts. In addition to being a NAIFA member, I am also a financial and insurance advisor (Registered Investment Advisor - RIA) with a financial & insurance planning firm in Needham, MA. I have been in the financial and insurance planning business, specializing in insurance and investment planning for over 23 years and have insured many clients within the Commonwealth of MA.

I support a nationwide, uniform "best interest" standard of care for securities recommendations and transactions. The SEC's recently adopted Regulation Best Interest (Reg BI) establishes a workable national best interest standard of conduct that provides a significant strengthening of the standard of care for broker-dealers and their representatives while also preserving the existing business models (advisory and brokerage) that consumers want and need. In addition, the National Association of Insurance Commissioners is in the final stages of amending its model regulation on annuity recommendations and sales to include a best interest standard that aligns well with the SEC's Reg BI. These regulatory actions by the SEC and the NAIC will accomplish both regulator's and industry's goal of protecting our clients while also preserving a business model that is appropriate for agents and advisors.

The current proposal from your office, by contrast, is flawed. At a high level, some of the key concerns with your proposal are as follows:
· The proposal increases consumers' costs while decreasing consumer choice.
· The proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.
· The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and
responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
· Since most fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
· The proposal may also limit consumer choices on annuity and life insurance products. The additional costs associated with complying with this regulation may ultimately reduce the performance of these products.
· The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

NAIFA has always been most concerned about giving our clients the best service and advice possible given each of our clients' particular situations. As we all know there is no one strategy that works for every client and we support regulation that allows our clients to have a choice of both strategy and the method of receiving advice and accessing products that best fits their own needs.

*The National Association of Insurance and Financial Advisors (NAIFA) Massachusetts over 470 members statewide who are licensed insurance agents and financial advisors who focus their practices on one or more of the following: long term care insurance, disability insurance, life insurance and annuities, health insurance and employee benefits, multiline, and financial advising and investments

Sincerely,

Michael Elcock
The Bulfinch Group

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Timothy Leveroni

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Timothy Leveroni
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Sandra Gilpatrick

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Sandra Gilpatrick
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Chris Sheehan

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Chris Sheehan
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Kathryn Dunlop

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Kathryn Dunlop
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Dallas Coffman

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Dallas Coffman
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Marioleni Mandelis

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Marioleni Mandelis
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Matthew Schwartz

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Matthew Schwartz
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Cheryl Fonseca

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Cheryl Fonseca
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Robert Matson

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Robert Matson
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Mark Linnane

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Mark Linnane
Bay Financial Associates and our Broker Dealer is LPL

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Robert Shepherd

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Robert Shepherd
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Samir Shah

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Samir Shah
LPL Financial, Leveroni Financial Management

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Alan Ioffredo

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Alan Ioffredo
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Edward Quirk

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Edward Quirk
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Lee Generous

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Lee Generous
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Mark Bilodeau

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Mark Bilodeau
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Timothy Leveroni

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Timothy Leveroni
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Philip Mathey

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Philip Mathey
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Michelle Griffin

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michelle Griffin
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Angelo Anello

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Angelo Anello
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Deborah Goodman

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Deborah Goodman
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Erick DeCastro

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Erick DeCastro
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Catherine Valega

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Catherine Valega
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: John Sawyer

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

John Sawyer
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Daniel Leveroni

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Daniel Leveroni
LPL Financial
Leveroni Financial Management Corporation

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Steven Nowicki

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Steven Nowicki
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Julian Morris

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Julian Morris
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Michael Poggi

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Poggi
LPL Financial

Alternative-and-Direct-Investment-Securities-Association.pdf (PDF)

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Joseph Ferreira

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Joseph Ferreira
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Brian Ruttle

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Brian Ruttle
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Rachael Linnehan

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Rachael Linnehan
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Paul LaGreca Jr

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Paul LaGreca Jr
LaGreca Wealth Management

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Will Hackler

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Will Hackler
Integrate Pension Services, Inc.

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Jonathan Sudkin

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jonathan Sudkin
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Robert Spadano

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Robert Spadano
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: John Florence

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

John Florence
LPL Financial

Subject: No MA Fiduciary Rule-Less Choice for Consumers
From: Francis Saba
34 Longfellow Road
Shrewsbury,MA 01545
Mobile Phone-508-259-2873
Profession-Retired Hospital CEO,now part time consultant for Riverside Community Care

Dear Secretary Galvin:
Thank you for all that you do to protect our interests as consumers in the Commonwealth of Massachusetts- we are very fortunate to have you as our advocate and as a vigilant watchdog on our behalf.

1.The Securities and Exchange Commission's(SEC) Regulation Best Interest already provides a significant strengthening of the standard of care for broker-dealers and their representatives,while also preserving the existing business models that I feel adequately protect us as consumers. The SEC's new regulation coupled with the soon-to-be final amendments to the National Association of Insurance Commissioners'(NAIC) suitability in Annuities Transaction Model Regulation will provide significant enhancements to consumer protection in a uniform and consistent manner. It's possible that individual state action,like that being proposed in Massachusetts,might lead to overlapping or conflicting requirements.

2.The state proposal strongly favors a fee-based business model over a commission-based one and this strategy may have an adverse effect on small and mid level investors who do not meet the minimum asset requirements of $250,000; $500,000 or more- levels of investment required by fee only advisers. This may discourage small investors from seeking advice and guidance regarding savings strategies.

3.Unbiased and honest advice from broker dealers,agents,and investment advisers without regard to the financial or other interest of any party other than the client is critical as the state's proposed regulation mandates,but in this regard the state's proposed regulation seems somewhat vague and overly broad.

In summary,my belief is that the SEC's Regulation Best Interest along with the amendments proposed by the NAIC will more than adequately protect consumers' interests and provide for important choices in both the strategy and method of receiving investment advice and in accessing products.

Thank you kindly for considering my comments.

Respectfully, Francis M.Saba

Subject: Pending legistation
From: Fred Saltzberg

The bill discriminates against them folks with less than300k in ira or money for investing and forces those with 500k to pay a fee Eliminates a free market system

Fred Saltzberg
Fsalt01@aol.com

Subject: Comments on Proposed Fiduciary Conduct Standard for Broker-Dealers, Agents, Investment Advisers, and Investment Adviser Representatives (950 CMR 12.200)
From: Gary Pence
Dear Secretary Galvin:

I write to you today as an employee of a financial services firm who believes in the importance of putting investors' interests ahead of mine or my company's interests. As such, I fully support the establishment of an enhanced standard of conduct for financial professionals. Rather than adding to the regulatory regime, I believe this can be achieved through implementation of the Securities and Exchange Commission's (SEC) Regulation Best Interest "Reg BI" and the National Association of Insurance Commissioners' (NAIC) model regulation governing annuity sales practices.

Finalized and adopted in June 2019, the SEC's Regulation Best Interest would substantially improve protections for investors while protecting investors' choices through access to products and services. Likewise, the NAIC's model regulation, slated for completion in early 2020, would provide similar enhancements to investor protections. Already, financial services firms are updating their training materials to help financial professionals fully understand how to meet these new requirements by: amending their policies and procedures to align with Reg BI; putting new policies and procedures in place to more effectively protect investors by identifying and mitigating or eliminating conflicts of interest; and creating user-friendly disclosures to help my clients make informed decisions. I am confident that the changes made by the NAIC's updated model will similarly enhance protections for investors.

I urge you to delay the adoption of your proposal so you can carefully study and assess whether Reg BI and the NAIC model will effectively achieve the goals of your proposal. I also urge you to allow Reg BI and the NAIC model to be in effect for a reasonable amount of time before reaching any conclusions about their effectiveness in protecting investors.

Thank you for the opportunity to share my thoughts on this important issue.

Sincerely,
Gary Pence

Subject: MA FIDUCIARY RULE is BAD for Consumers
From: Peter Magni

Good Afternoon Secretary Galvin:

My name is Peter R. Magni, and I am a member of the local Massachusetts chapter of the National Association of Insurance and Financial Advisors (NAIFA)*.  NAIFA –MA has over 470 licensed insurance and financial planners doing business with your constituents in the Commonwealth of Massachusetts.  In addition to being a NAIFA member, I am also a financial and insurance advisor with a financial & insurance planning firm in Needham, MA.  I have been in the financial and insurance planning business, specializing in insurance and investment planning for 37 years and have insured many clients within the Commonwealth of MA.

I support a nationwide, uniform "best interest" standard of care for securities recommendations and transactions. The SEC's recently adopted Regulation Best Interest (Reg BI) establishes a workable national best interest standard of conduct that provides a significant strengthening of the standard of care for broker-dealers and their representatives while also preserving the existing business models (advisory and brokerage) that consumers want and need. In addition, the National Association of Insurance Commissioners is in the final stages of amending its model regulation on annuity recommendations and sales to include a best interest standard that aligns well with the SEC's Reg BI. These regulatory actions by the SEC and the NAIC will accomplish both regulator's and industry's goal of protecting our clients while also preserving a business model that is appropriate for agents and advisors.

The current proposal from your office, by contrast, is flawed.  At a high level, some of the key concerns with your proposal are as follows:

• The proposal increases consumers' costs while decreasing consumer choice.
• The proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.
• The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
• Since most fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
• The proposal may also limit consumer choices on annuity and life insurance products.  The additional costs associated with complying with this regulation may ultimately reduce the performance of these products. 
• The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts  Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

NAIFA has always been most concerned about giving our clients the best service and advice possible given each of our clients' particular situations.  As we all know there is no one strategy that works for every client and we support regulation that allows our clients to have a choice of both strategy and the method of receiving advice and accessing products that best fits their own needs.

*The National Association of Insurance and Financial Advisors (NAIFA) Massachusetts over 470 members statewide who are licensed insurance agents and financial advisors who focus their practices on one or more of the following: long term care insurance, disability insurance, life insurance and annuities, health insurance and employee benefits, multiline, and financial advising and investments.

Peter
Peter R. Magni, LUTCF
The Bulfinch Group

Subject: Fiduciary Regulation
From: Doug DiCerbo

I have some concerns about the proposal set forth by the Secretary of the Commonwealth William Galvin. They are as follows:

This proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.

• The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
• Since most fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
• The proposal may also limit consumer choices on annuity and life insurance products. The additional costs associated with complying with this regulation may ultimately reduce the performance of these products.
• The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

At NAIFA we have always been most concerned about giving our clients the best service and advice possible given each of our clients' particular situations. There is no one strategy that works for every client and we support regulation that allows our clients to have a choice of both strategy and the method of receiving advice and accessing products that best fits their own needs.

Regards,
Doug DiCerbo

Subject: Fiduciary Rule Commentary
From: Robert Basiri

My name is Robert Basiri, and I am a member of the local NAIFA Massachusetts chapter. I have been in the business for 11 years, and have based my practice around comprehensive financial planning which has included both commissionable and fee-based advice which currently services over 400 households across several different markets and socio-economic classes.

I am in extreme favor of the SEC's Reg BI-- I believe that all advisors, in all capacities should always be working in the utmost interest of their clients and client's families. However, I am extremely disappointed in the current proposal from your office, please take a moment to read some of these bullet points:

• Fee-only advice is typically significantly more expensive to the consumer in the long run. While this financially benefits the broker dealers and advisory practices, it can decimate some of our client's accounts who do not necessarily need, or want to pay on-going fees for service.
• Fee-only advice also generally limits the consumer's options-- not all open-ended companies and insurance companies/annuity providers will offer this fee-only service option and therefore will not allow the advisor to maintain his/her fiduciary standard by preforming due-diligence on all available products and planning options.
• Fee-only advice is not currently streamlined across broker-dealers regarding a breakpoint schedule. Most advisors will choose, along with their broker dealers a specific breakpoint in AUM per client/household where their fees may be discounted. This is up to each advisor within each broker dealer with few, if any B/D specific fee adjustments made based on the sizes of each account. With many commissionable products, including but not limited to Class A Mutual Funds, there is an official breakpoint schedule, easily found made available to the public within the prospectus and summary prospectus.

Thanks so much for your time and consideration, I trust the best decision will be made for the people of Massachusetts.

--Robbie.
Robert C. Basiri, RICP®

Subject: NO MA Fiduciary Rule - LESS CHOICE FOR CONSUMERS
From: Adam Marino

Good Morning Secretary Galvin-

My name is Adam Marino, and I am a member of the local Massachusetts chapter of the National Association of Insurance and Financial Advisors (NAIFA)*. NAIFA –MA has over 470 licensed insurance and financial planners doing business with your constituents in the Commonwealth of Massachusetts. In addition to being a NAIFA member, I am also a Financial Planner, providing fee based planning, a licensed Insurance Agent, and a Registered Representative providing commission based options when appropriate. I have been in the financial advisory and insurance business working with the same firm currently located in Needham for 11 years.

NAIFA Massachusetts and NAIFA support a nationwide, uniform "best interest" standard of care for securities recommendations and transactions. The SEC's recently adopted Regulation Best Interest (Reg BI) establishes a workable national best interest standard of conduct that provides a significant strengthening of the standard of care for broker-dealers and their representatives while also preserving the existing business models (advisory and brokerage) that consumers want and need. In addition, the National Association of Insurance Commissioners is in the final stages of amending its model regulation on annuity recommendations and sales to include a best interest standard that aligns well with the SEC's Reg BI. These regulatory actions by the SEC and the NAIC will accomplish both regulator's and industry's goal of protecting our clients while also preserving a business model that is appropriate for agents and advisors.

The current proposal from your office, by contrast, is flawed. At a high level, some of the key concerns with your proposal are as follows:

• The proposal increases consumers' costs while decreasing consumer choice.
• The proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.
• The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
• Since many fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
• The proposal may also limit consumer choices on annuity and life insurance products. The additional costs associated with complying with this regulation may ultimately reduce the performance of these products.
• The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

NAIFA has always been most concerned about giving our clients the best service and advice possible given each of our clients' particular situations. As we all know there is no one strategy that works for every client and we support regulation that allows our clients to have a choice of both strategy and the method of receiving advice and accessing products that best fits their own needs.

*The National Association of Insurance and Financial Advisors (NAIFA) Massachusetts over 470 members statewide who are licensed insurance agents and financial advisors who focus their practices on one or more of the following: long term care insurance, disability insurance, life insurance and annuities, health insurance and employee benefits, multiline, and financial advising and investments.

Respectfully,

-Adam
Adam P. Marino, CFP®, CLTC

Subject: Comments on Proposed Fiduciary Conduct Standard for Broker-Dealers, Agents, Investment Advisers, and Investment Adviser Representatives (950 CMR 12.200)
From: Renee West

Dear Secretary Galvin:

Secretary Galvin:

I write to you today as an employee of a financial services firm who believes in the importance of putting investors' interests ahead of mine or my company's interests. As such, I fully support the establishment of an enhanced standard of conduct for financial professionals. Rather than adding to the regulatory regime, I believe this can be achieved through implementation of the Securities and Exchange Commission's (SEC) Regulation Best Interest "Reg BI" and the National Association of Insurance Commissioners' (NAIC) model regulation governing annuity sales practices.

Finalized and adopted in June 2019, the SEC's Regulation Best Interest would substantially improve protections for investors while protecting investors' choices through access to products and services. Likewise, the NAIC's model regulation, slated for completion in early 2020, would provide similar enhancements to investor protections. Already, financial services firms are updating their training materials to help financial professionals fully understand how to meet these new requirements by: amending their policies and procedures to align with Reg BI; putting new policies and procedures in place to more effectively protect investors by identifying and mitigating or eliminating conflicts of interest; and creating user-friendly disclosures to help my clients make informed decisions. I am confident that the changes made by the NAIC's updated model will similarly enhance protections for investors.

I urge you to delay the adoption of your proposal so you can carefully study and assess whether Reg BI and the NAIC model will effectively achieve the goals of your proposal. I also urge you to allow Reg BI and the NAIC model to be in effect for a reasonable amount of time before reaching any conclusions about their effectiveness in protecting investors.

Thank you for the opportunity to share my thoughts on this important issue.

Sincerely,
Renee West

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: John Kerr

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

John Kerr
Financial Associates

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Pete Lounsbury

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Pete Lounsbury
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Sarin Barsoumian

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Sarin Barsoumian
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Stephen Guy

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Stephen Guy
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Andrew Brzozowski

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Andrew Brzozowski
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Kenneth Lefebvre

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Kenneth Lefebvre
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Timothy Demeritt

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Timothy Demeritt
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Dan Muscatello

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Dan Muscatello
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Sean Mackey

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Sean Mackey
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Joseph Deluca

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Joseph Deluca
LPL Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Joseph Peppe

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Joseph Peppe
Retirement Plans Consultant
Ameriprise Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Matthew Delaney

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Matthew Delaney
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: James Bianchi

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

James Bianchi
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Michael Kelley

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Kelley
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Kristine Koczajowski

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Kristine Koczajowski
Hometown Wealth Management (LPL Financial)

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Joanne Leveroni

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Joanne Leveroni
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Thomas Hitchcock

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Thomas Hitchcock
Bay Financial Associates

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Craig Christo

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Craig Christo
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Michael Dalton

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Dalton
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Penelope Tzougros

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Penelope Tzougros
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: David Gillespie

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

David Gillespie
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Gary Hultgren

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Gary Hultgren
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Kelly Thomas

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Kelly Thomas
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Joseph Donovan

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Joseph Donovan
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: James T. Wilcox Jr.

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

James T. Wilcox Jr.
LPL Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Manish Nigam

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Manish Nigam
Director - Data Science
Ameriprise Financial

Subject: Proposed Fiduciary Standard in Massachusetts00)
From: Brian O'Sullivan

Dear Secretary Galvin:

My name is Brian O'Sullivan and I have been an advisor in Massachusetts for over 25 years. I have concern and object to the Fiduciary Standard proposed by your office. I have always made recommendations to my clients that were in their best interests. I believe the vast majority of advisors do the same and offer best advice and choice to their clients. The standard that you are proposing is not well thought out and may cause adverse impact to the those that need advice and counsel for their financial planning the most.

Please see some of the concerns below. I ask that you seek out and review input and comments from advisors to insure that any standard put in place works for all.

• The proposal increases consumers' costs while decreasing consumer choice
• The proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.
• The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
• Since many fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
• The proposal may also limit consumer choices on annuity and life insurance products. The additional costs associated with complying with this regulation may ultimately reduce the performance of these products.
• The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

Best regards,
Brian W. O'Sullivan, CFP, CLU, ChFC

Subject: Comments on Proposed Fiduciary Conduct Standard for Broker-Dealers, Agents, Investment Advisers, and Investment Adviser Representatives (950 CMR 12.200)
From: Gregg Libutti

Dear Secretary Galvin:

Secretary Galvin:

I write to you today as an employee of a financial services firm who believes in the importance of putting investors' interests ahead of mine or my company's interests. As such, I fully support the establishment of an enhanced standard of conduct for financial professionals. Rather than adding to the regulatory regime, I believe this can be achieved through implementation of the Securities and Exchange Commission's (SEC) Regulation Best Interest "Reg BI" and the National Association of Insurance Commissioners' (NAIC) model regulation governing annuity sales practices.

Finalized and adopted in June 2019, the SEC's Regulation Best Interest would substantially improve protections for investors while protecting investors' choices through access to products and services. Likewise, the NAIC's model regulation, slated for completion in early 2020, would provide similar enhancements to investor protections. Already, financial services firms are updating their training materials to help financial professionals fully understand how to meet these new requirements by: amending their policies and procedures to align with Reg BI; putting new policies and procedures in place to more effectively protect investors by identifying and mitigating or eliminating conflicts of interest; and creating user-friendly disclosures to help my clients make informed decisions. I am confident that the changes made by the NAIC's updated model will similarly enhance protections for investors.

I urge you to delay the adoption of your proposal so you can carefully study and assess whether Reg BI and the NAIC model will effectively achieve the goals of your proposal. I also urge you to allow Reg BI and the NAIC model to be in effect for a reasonable amount of time before reaching any conclusions about their effectiveness in protecting investors.

Thank you for the opportunity to share my thoughts on this important issue.

Sincerely,

Sincerely,
Gregg Libutti

Subject: 01062020 MA Fiduciary Proposal
From: Patrick Kane

Dear Secretary William Galvin:

Subject: Comments on Proposed Fiduciary Conduct Standard for Broker-Dealers, Agents, Investment Advisers, and Investment Adviser Representatives (950 CMR 12.200)

I write to you today as an employee (or agent) of a financial services firm who believes in the importance of putting investors' interests ahead of the financial professional's or company's interests. As such, I fully support the establishment of an enhanced standard of conduct for financial professionals. Rather than adding to the regulatory regime, I believe this can be achieved through implementation of the Securities and Exchange Commission's (SEC) Regulation Best Interest "Reg BI" and the National Association of Insurance Commissioners' (NAIC) model regulation governing annuity sales practices.

Finalized and adopted in June 2019, the SEC's Regulation Best Interest would substantially improve protections for investors while protecting investors' choices through access to products and services. Likewise, the NAIC's model regulation, slated for completion in early 2020, would provide similar enhancements to investor protections.

I urge you to delay the adoption of your fiduciary proposal so you can carefully study and assess whether Reg BI and the NAIC model will effectively achieve the goals of your proposal. I also urge you to allow Reg BI and the NAIC model to be in effect for a reasonable amount of time before reaching any conclusions about their effectiveness in protecting investors.

Thank you for the opportunity to share my thoughts on this important issue.

Sincerely,
Patrick Kane

Subject: 01062020 MA Fiduciary Proposal
From: Mark Kinbacke

Dear Secretary William Galvin:

Subject: Comments on Proposed Fiduciary Conduct Standard for Broker-Dealers, Agents, Investment Advisers, and Investment Adviser Representatives (950 CMR 12.200)

I write to you today as an employee (or agent) of a financial services firm who believes in the importance of putting investors' interests ahead of the financial professional's or company's interests. As such, I fully support the establishment of an enhanced standard of conduct for financial professionals. Rather than adding to the regulatory regime, I believe this can be achieved through implementation of the Securities and Exchange Commission's (SEC) Regulation Best Interest "Reg BI" and the National Association of Insurance Commissioners' (NAIC) model regulation governing annuity sales practices.

Finalized and adopted in June 2019, the SEC's Regulation Best Interest would substantially improve protections for investors while protecting investors' choices through access to products and services. Likewise, the NAIC's model regulation, slated for completion in early 2020, would provide similar enhancements to investor protections.

I urge you to delay the adoption of your fiduciary proposal so you can carefully study and assess whether Reg BI and the NAIC model will effectively achieve the goals of your proposal. I also urge you to allow Reg BI and the NAIC model to be in effect for a reasonable amount of time before reaching any conclusions about their effectiveness in protecting investors.

Thank you for the opportunity to share my thoughts on this important issue.

Sincerely,
Mark Kinback

Subject: 01062020 MA Fiduciary Proposal
From: Noel Anderson

Dear Secretary William Galvin:

Subject: Comments on Proposed Fiduciary Conduct Standard for Broker-Dealers, Agents, Investment Advisers, and Investment Adviser Representatives (950 CMR 12.200)

I write to you today as an employee (or agent) of a financial services firm who believes in the importance of putting investors' interests ahead of the financial professional's or company's interests. As such, I fully support the establishment of an enhanced standard of conduct for financial professionals. Rather than adding to the regulatory regime, I believe this can be achieved through implementation of the Securities and Exchange Commission's (SEC) Regulation Best Interest "Reg BI" and the National Association of Insurance Commissioners' (NAIC) model regulation governing annuity sales practices.

Finalized and adopted in June 2019, the SEC's Regulation Best Interest would substantially improve protections for investors while protecting investors' choices through access to products and services. Likewise, the NAIC's model regulation, slated for completion in early 2020, would provide similar enhancements to investor protections.

I urge you to delay the adoption of your fiduciary proposal so you can carefully study and assess whether Reg BI and the NAIC model will effectively achieve the goals of your proposal. I also urge you to allow Reg BI and the NAIC model to be in effect for a reasonable amount of time before reaching any conclusions about their effectiveness in protecting investors.

Thank you for the opportunity to share my thoughts on this important issue.

Sincerely,
Noel Anderson

Subject: 01062020 MA Fiduciary Proposal
From: John Krom

Dear Secretary William Galvin:

Subject: Comments on Proposed Fiduciary Conduct Standard for Broker-Dealers, Agents, Investment Advisers, and Investment Adviser Representatives (950 CMR 12.200)

I write to you today as an employee (or agent) of a financial services firm who believes in the importance of putting investors' interests ahead of the financial professional's or company's interests. As such, I fully support the establishment of an enhanced standard of conduct for financial professionals. Rather than adding to the regulatory regime, I believe this can be achieved through implementation of the Securities and Exchange Commission's (SEC) Regulation Best Interest "Reg BI" and the National Association of Insurance Commissioners' (NAIC) model regulation governing annuity sales practices.

Finalized and adopted in June 2019, the SEC's Regulation Best Interest would substantially improve protections for investors while protecting investors' choices through access to products and services. Likewise, the NAIC's model regulation, slated for completion in early 2020, would provide similar enhancements to investor protections.

I urge you to delay the adoption of your fiduciary proposal so you can carefully study and assess whether Reg BI and the NAIC model will effectively achieve the goals of your proposal. I also urge you to allow Reg BI and the NAIC model to be in effect for a reasonable amount of time before reaching any conclusions about their effectiveness in protecting investors.

Thank you for the opportunity to share my thoughts on this important issue.

Sincerely,
John Krom

Subject: Reconsider new provision to 950 CMR 12,200.
From: Dan Babine

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Dan Babine

Subject: Reconsider new provision to 950 CMR 12,200.
From: Karen Mazukina

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Karen Mazukina

Subject: Reconsider new provision to 950 CMR 12,200.
From: Timothy Tracy

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Timothy Tracy

Subject: Reconsider new provision to 950 CMR 12,200.
From: Bogdan Siekirka

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Bogdan Siekirka

Subject: Reconsider new provision to 950 CMR 12,200.
From: Pete Walsh

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Pete Walsh

Subject: Reconsider new provision to 950 CMR 12,200.
From: Jackson Leung

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Jackson Leung

Subject: Reconsider new provision to 950 CMR 12,200.
From: Lauren Oliveira

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Lauren Oliveira

Subject: Reconsider new provision to 950 CMR 12,200.
From: Sam Dowd

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Sam Dowd

Subject: Reconsider new provision to 950 CMR 12,200.
From: Andrew Rudman

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Andrew Rudman

Subject: Reconsider new provision to 950 CMR 12,200.
From: Jared Barilaro

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Jared Barilaro

Subject: Reconsider new provision to 950 CMR 12,200.
From: Kim Daley Lamirande

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Kim Daley Lamirande

Subject: Reconsider new provision to 950 CMR 12,200.
From: Robyn Sartell

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Robyn Sartell

Subject: Reconsider new provision to 950 CMR 12,200.
From: Carroll Crispo

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Carroll Crispo

Subject: Reconsider new provision to 950 CMR 12,200.
From: John Kuhn

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
John Kuhn

Subject: Reconsider new provision to 950 CMR 12,200.
From: Gabe Anthony

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Gabe Anthony

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Patrick Clunan

Dear Secretary Galvin:

I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Patrick Clunan
Program Manager, Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Steven Swinhart

Dear Secretary Galvin:

I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Steven Swinhart
Senior Manager Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Karen Bamber

Dear Secretary Galvin:

I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Karen Bamber
Sr. Operations Manager
Columbia Threadneedle Investments/Ameriprise Financial

Subject: Reconsider new provision to 950 CMR 12,200.
From: David Shapiro

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
David Shapiro

Subject: Reconsider new provision to 950 CMR 12,200.
From: Angela Whitcher

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Angela Whitcher

Subject: Reconsider new provision to 950 CMR 12,200.
From: Miguel Ribeiro

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Miguel Ribeiro

Comments on Proposed Fiduciary Conduct Standard (PDF)

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Stephen Harmon

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Stephen Harmon
Internal Advisor Consultant Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Joseph Buonadonna

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Joseph Buonadonna
Director, National Account Manager
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Alicia Distler

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Alicia Distler SVP
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Michael Dimare

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Michael Dimare
Institutional Sales Analyst
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Steven Healey

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Steven Healey
Financial Advisor
Ameriprise

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Erik Butler

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Erik Butler
RFP specialist
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Marc Albano

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Marc Albano
Director Compensation
Ameriprise Financial/Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Laurence Tuot

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Laurence Tuot
Director, Program Management Technology
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Matthew Sullivan

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Matthew Sullivan
Performance Analytics manager
Ameriprise Financial / Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Jaime Barnes

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jaime Barnes
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Paul D'Ambrosio

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Paul D'Ambrosio
Associate Counsel
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Lisa Feuerbach

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Lisa Feuerbach
Manager, Media Relations
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Teresa Lirio

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Teresa Lirio
Legal Affairs Manager
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Daniel Boncarosky

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Daniel Boncarosky
Portfolio Manager
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: David Spitz

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

David Spitz
Product Manager
Columbia Threadneedle

Subject: Protect Consumer Choice and Retirement Savings!
From: Michelle Spaziani

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michelle A. Spaziani, CFP®
Founder and CEO, Summit Behavioral Wealth, LLC Financial Planner, RJFS Raymond James Financial Services

Subject: Protect Consumer Choice and Retirement Savings!
From: Stephen Hollingsworth

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Stephen Hollingsworth RIA
Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Rovena Ashiku

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Rovena Ashiku
Sr. Director
Ameriprise Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Beth Sweeney

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Beth Sweeney
Managing Director
Steward Partners & Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Daniel Milligan

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Daniel Milligan
Director - US Product Development and Strategy
Columbia Threadneedle Investments

Subject: Protect Consumer Choice and Retirement Savings!
From: Chris Stafford

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Chris Stafford
Financial Advisor
Raymond James

Subject: Protect Consumer Choice and Retirement Savings!
From: Jay Jackson

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jay Jackson
Strategy and Innovation
Cetera

Subject: Protect Consumer Choice and Retirement Savings!
From: Christian Clifford

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Christian Clifford
Vice President
Raymond James

Subject: Protect Consumer Choice and Retirement Savings!
From: Daniel Wagner

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Daniel Wagner
Financial Advisor
Ameriprise

Subject: Protect Consumer Choice and Retirement Savings!
From: Jason Mullane

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jason Mullane
Private Wealth Advisor
Ameriprise Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Sebastian Gonzalez

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Sebastian Gonzalez
Financial Advisor
Ameriprise Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Thomas Curran

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Thomas Curran
Vice President Financial Advisor
Ameriprise

Subject: Protect Consumer Choice and Retirement Savings!
From: John Rhoades

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

John Rhoades
Financial Advisor
Ameriprise Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Jonathan Jackson

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jonathan Jackson
Field Vice President
Ameriprise Financial Services

Subject: Protect Consumer Choice and Retirement Savings!
From: Jonathan Farnham

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jonathan Farnham
Financial Advisor
Ameriprise Financial Services,Inc

Subject: Protect Consumer Choice and Retirement Savings!
From: Susan Karsch

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Susan Karsch
Financial Advisor
Ameriprise

Subject: Protect Consumer Choice and Retirement Savings!
From: Bill Cratty

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Bill Cratty CFP
Financial Advisor
Ameriprise Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Sean Todd

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Sean Todd
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Edward Marshall

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Edward Marshall
Financial Advisor
Ameriprise

Subject: Protect Consumer Choice and Retirement Savings!
From: Graham Tower

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Graham Tower
Financial Planner
Ameriprise

Subject: Protect Consumer Choice and Retirement Savings!
From: Garth Fondo

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Garth Fondo CFP
Ameriprise

Subject: Protect Consumer Choice and Retirement Savings!
From: David Nicholson

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

David Nicholson
Financial Advisor
Nicholson Financial Services, Inc./Raymond James Financial Services, Inc.

Subject: Protect Consumer Choice and Retirement Savings!
From: Ian O'Neal

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Ian O'Neal Md
Raymond James

Subject: Protect Consumer Choice and Retirement Savings!
From: Stephen Coffey

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Stephen Coffey
Financial Advisor, CERTIFIED FINANCIAL PLANNER
Ameriprise Financial Services, Inc

Subject: Protect Consumer Choice and Retirement Savings!
From: David Lessner

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

David Lessner
Financial Advisor
Raymond James

Subject: Protect Consumer Choice and Retirement Savings!
From: Sean FLynn

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Sean FLynn
Investment Strategist and Investment Committee Chair
Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Kristin Weisser

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Kristin Weisser
Senior Director
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Tim Reitzenstein

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Tim Reitzenstein
Internal Advisor Consultant
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Jeanelle Plouffe

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Jeanelle Plouffe
Senior Manager - Performance Analytics
Ameriprise - Columbia Threadneedle Investments

Subject: Protect Consumer Choice and Retirement Savings!
From: Kevin Connors

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Kevin Connors
Private Wealth Advisor
Ameriprise Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Samuel Lookner

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Samuel Lookner
Financial Advisor
Ameriprise Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Anne-Marie McCormick

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Anne-Marie McCormick
Practice Manager, CRPC, FPQP
Ameriprise Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Timothy Corkum

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Timothy Corkum
Financial Planner
Ameriprise Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Roger Cummings

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Roger Cummings
Certified Financial Planner
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Lisa Mobilia

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Lisa Mobilia
Senior Administrative Assistant
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Matthew Ferrelli

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Matthew Ferrelli
Portfolio Manager
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: William Callagy

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

William Callagy
Portfolio Manager
Columbia Threadneedle Investments

Subject: Protect Consumer Choice and Retirement Savings!
From: Frank Addonizio

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Frank Addonizio CFP, APMA, CRPC
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Julie Nickerson

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Julie Nickerson
Senior Business Analyst
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Tchintcia Barros

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Tchintcia Barros
Portfolio Equity Portfolio
Ameriprise Financials

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Gregg Smalley

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Gregg Smalley
Senior Equity Research Analyst
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Lindsay Willard

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Lindsay Willard
Senior Manager of Graphic Design
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Josh Kapp

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Josh Kapp
Senior Analyst
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Amanda Beddia

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Amanda Beddia
Senior Administrative Assistant
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Richard Manuel

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Richard Manuel
Equity Research Analyst - Financial Sector
Columbia Threadneedle

Subject: Protect Consumer Choice and Retirement Savings!
From: Tiffany Gauvin

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Tiffany Gauvin
Marketing Manager
Columbia Threadneedle

Subject: Protect Consumer Choice and Retirement Savings!
From: Hugh Mullin

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Hugh Mullin
Portfolio Manager
Columbia Threadneedle

Subject: Protect Consumer Choice and Retirement Savings!
From: Dan Steele

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Dan Steele, CIMA
Head of DCIO
Columbia Threadneedle Investments Ameriprise Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Michael Farley

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Farley
Marketing Manager
Columbia Threadneedle Investments (Ameriprise)

Subject: Protect Consumer Choice and Retirement Savings!
From: Suzanne King

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Suzanne King
Investment Strategist and Investment Committee Chair
Raymond James

Subject: Protect Consumer Choice and Retirement Savings!
From: Lisa Whitman

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Lisa Whitman
Director, Marketing
Columbia Threadneedle

Subject: Protect Consumer Choice and Retirement Savings!
From: Surabhi Ahmad

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Surabhi Ahmad
VP - Compliance
Ameriprise Financial and Columbia Threadneedle Investments

Subject: Protect Consumer Choice and Retirement Savings!
From: Jennifer Hamilton

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jennifer Hamilton
Region Coordinator
Ameriprise Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: George Norcross

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

George Norcross
Vice President, National Account Manager
Ameriprise/Columbia Threadneedle Investments

Subject: Protect Consumer Choice and Retirement Savings!
From: William Truscott

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

William Truscott
CEO
Columbia Threadneedle Investments and Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Anthony Salerno

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Anthony Salerno
VP, Financial Consultant
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Kelly Collins

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Kelly Collins
Registered Operations Leader
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Jay Gordon

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jay Gordon
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Matthew Rich

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Matthew Rich
Counsel
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Ryan McCabe

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Ryan McCabe
Managing Partner
Ameriprise Financial Services, Inc

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Keith Weinstein

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Keith Weinstein
Associate Manager
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Robert Cotter

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Robert Cotter
RFP Writer
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Scott Illingsworth

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Scott Illingsworth
Financial Advisor, CFP
Ameriprise Financial Services

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Ryan Hazel

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Ryan Hazel
Financial Advisor
Ameriprise Financial Services

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Jay Woerdeman

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jay Woerdeman
Private Wealth Advisor/Owner
The Woerdeman Financial Group Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Stephanie Lynne

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Stephanie Lynne
LPL

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Christine DelBrocco

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Christine DelBrocco
Financial Advisor
Ameriprise Financial Services, Inc

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Stephen Craig

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Stephen Craig
Managing Director
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Jessica Crooker

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Jessica Crooker
Senior Equity Trader
Ameriprise

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Mark Braley

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Mark Braley, CFA
Vice President, Information Strategy and Management |Head of Information Management, Reporting & Delivery | Business Intelligence and Analytics
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Kevin Howley

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Kevin Howley
Director - Equity Product Management
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Kimberly Campbell

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Kimberly Campbell
Sr. Portfolio Manager
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Irene Garand

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Irene Garand
Certified Financial Planner
Ameriprise Financial Services, Inc

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Michael Carnevale

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Carnevale
Branch Manager/Financial Advisor
Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Michael Hulett

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Hulett
Vice President Financial Advisor
Boston Harbor Wealth Advisors Raymond James Financial Services

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Gary McGovern

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Gary McGovern
Branch Manager, Sr. Vice President Investments
Raymond James Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Reed Spencer

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Reed Spencer
Investment Banking Associate
Raymond James & Associates

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Matthew Sachar

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Matthew Sachar
Financial Planner
Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Lisa Wolf

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Lisa Wolf
Financial Planning Specialist
Ameriprise

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Barry Forman

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Barry Forman
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Aaron Gerstel

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Aaron Gerstel
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Christine Douglass

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Christine Douglass
Paraplanner
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Todd Darling

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Todd Darling
Branch Manager, Financial Advisor, CFP
Ameriprise Financial, CFP Board

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Christopher Civale

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Christopher Civale
Private Wealth Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Michael Welch

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Welch
Financial Advisor
Ameriprise

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Matt Neely

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Matt Neely
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Rohan Mehta

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Rohan Mehta
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Jennifer Gray

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jennifer Gray
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Stephen Gesualdi

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Stephen Gesualdi
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: James Carey

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

James Carey
CFP
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Paul Guinee

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Paul Guinee
Financial Planner
Ameriprise Financial Advisors

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Edward Karsch

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Edward Karsch
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Jeffrey Wakefield

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jeffrey Wakefield
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Robert Neilson

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Robert Neilson
Sr. Director of Performance
ColumbiaThreadneedle I

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Jody Conroy

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Jody Conroy
Client Service Associate
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Peter Alberding

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Peter Alberding
Senior Vice-President, Investments, Branch Manager
Raymond James &p; Associates

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: John Donaruma

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

John Donaruma
Financial Advisor
Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Zack Thebeau

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Zack Thebeau
Internal Advisor Consultant
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Katherine Balnis

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Katherine Balnis
Senior Business Systems Analyst
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Madeline McCubbin

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Madeline McCubbin
Marketing Manager
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Steven O'Reilly

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Steven O'Reilly
Director of Product Strategy and Development
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Jefferson Correia

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jefferson Correia
Financial Advisor and Certified Financial Planner CFP
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Sharon Hughes

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Sharon Hughes
SVP, Internal Communications
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Charles Chiesa

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Charles Chiesa
Lead Business Analyst
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Fania Naccour

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Fania Naccour
Senior Audit Manager
Ameriprise Financial and CTI

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Catherine Johnson

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Catherine Johnson
Financial Advisor
Ameriprise Financial Services Inc

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Baxter Smith

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Baxter Smith
Baxter Smith CFP
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Matthew Stephan

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Matthew Stephan
Senior Analyst and Head of Municipal Bond Research
Columbia Threadneedle Investments, Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Laura Ego

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Laura Ego
Sr. Director, HR Business Partner
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Robert Perkoski

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Robert Perkoski
Senior Marketing Manager
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Patrick Mullins

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Patrick Mullins
Product Manager
Columbia Threadneedle
Certified Financial Planner

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Jeremy Javidi

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Jeremy Javidi
Portfolio Manager
ColumbiaThreadneedle

Subject: Advocacy Let
From: Robert McGinness

Jan 5, 2020

VIA e-mail to: securitiesregs-comments@sec.state.ma.us

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

To whom it may concern:

I am a resident of Massachusetts and a long-time investor. I have worked with individual financial advisers for many years, and they have provided me with valuable assistance in managing my investments and providing for my financial future. My current adviser has offered me different services and methods of compensation, giving me the flexibility to choose the type of services I want and the most cost-effective way to pay for them.

The Secretary of the Commonwealth and the Massachusetts Securities Division have recently proposed new regulations that will make it more difficult for me to work with my financial adviser by favoring certain business models over others, restricting access to products and services that I find valuable, and increasing the cost of services provided by financial advisers in Massachusetts. I understand the need for regulation of financial advisers, and have generally agreed with the approach of the Securities Division in taking actions to protect investors like me.   However, the proposed regulations will create many more problems than they solve and will not benefit most investors.

The U.S. Securities and Exchange Commission has recently enacted regulations that would provide many of the same investor protections that the Securities Division is trying to create, and the regulations proposed by the Division will be in direct conflict with those of the SEC. Massachusetts is not an island. It is part of an interconnected universe of individual investors like me. If the Division enacts regulations that are inconsistent with those of the SEC and other states, many financial advisers will choose not to do business in Massachusetts, harming me and many people like me. This is not in the interest of either investors or the Massachusetts economy. I strongly suggest that the Securities Division avoid adoption of regulations that are inconsistent with those of the SEC, and wait until the effects of the new SEC rules can be understood and evaluated. I also request that the Division avoid taking any action that will reduce access to products and services that I and many other investors find valuable and would like to continue receiving.

Thank you for your consideration.
Robert McGinness

Comments on Fiduciary Duty Proposal (PDF)

Subject: Protect Consumer Choice and Retirement Savings!
From: Frederick Lane

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Frederick Lane
Senior Vice President
Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Edward Lizotte

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Edward Lizotte CFP
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Lars Lambrecht

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Lars Lambrecht
Practice Manager
Oasis Financial

Subject: Fiduciary Duty of Broker-Dealers and Investment Advisers -
From: Jaimie Blackamn

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

Re: Fiduciary Duty of Broker-Dealers and Investment Advisers - Preliminary Proposal 950 CMR 12.204, 12.205, and 12.207
we welcome their participation in the discussion of how to strengthen investor protection while maintaining consumer choice and continued access to investment advice and products.

Approximately six weeks ago, the Securities and Exchange Commission ("SEC") adopted Regulation Best Interest ("Reg. BI") and a series of related regulations and interpretations regarding standards of conduct for broker-dealers and RIAs. Reg. BI establishes a comprehensive regime designed to enhance investor protection by requiring that broker-dealers not place their financial or other interests above those of their clients. A series of related new regulations require extensive disclosure about the services broker-dealers and RIAs provide, the capacit(ies) in which they are acting, fees and expenses, and conflicts of interest that may exist between the adviser and the client. While the SEC does not refer to Reg. BI as a fiduciary standard, it draws extensively on common law fiduciary principles and will produce the same practical results for most investors. Importantly, Reg. BI provides a clear and straightforward compliance roadmap for broker-dealers and other financial professionals.

In particular, we suggest that the Division delay further action with respect to adoption of new standards of conduct until it has taken the time to review and understand the full impact of Reg. BI.

Respectfully,

Jaimie Blackamn

Subject: Reconsider new provision to 950 CMR 12,200.
From: John Morin

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
John Morin

Subject: Reconsider new provision to 950 CMR 12,200
From: Gregg Forger

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Gregg Forger

To Whom it May Concern (PDF)

Subject: MA FIDUCIARY RULE is BAD for Consumers
From: William H. Altman

 Good Morning Secretary Galvin-

My name is William Altman, and I am a member of the local Massachusetts chapter of the National Association of Insurance and Financial Advisors (NAIFA)*.  NAIFA –MA has over 470 licensed insurance and financial planners doing business with your constituents in the Commonwealth of Massachusetts.  In addition to being a NAIFA member, I am also a financial and insurance advisor with a financial & insurance planning firm in Needham, MA.  I have been in the financial and insurance planning business, specializing in insurance and investment planning for years and have insured many clients within the Commonwealth of MA.

I support a nationwide, uniform "best interest" standard of care for securities recommendations and transactions. The SEC's recently adopted Regulation Best Interest (Reg BI) establishes a workable national best interest standard of conduct that provides a significant strengthening of the standard of care for broker-dealers and their representatives while also preserving the existing business models (advisory and brokerage) that consumers want and need. In addition, the National Association of Insurance Commissioners is in the final stages of amending its model regulation on annuity recommendations and sales to include a best interest standard that aligns well with the SEC's Reg BI. These regulatory actions by the SEC and the NAIC will accomplish both regulator's and industry's goal of protecting our clients while also preserving a business model that is appropriate for agents and advisors.

The current proposal from your office, by contrast, is  flawed.  At a high level, some of the key concerns with your proposal are as follows:

• The proposal increases consumers' costs while decreasing consumer choice.
• The proposal strongly favors a fee-based business model over a commission-based business model and imposes, in most instances, an ongoing fiduciary duty on commission based registered representatives. The resulting ongoing compliance costs  will likely lead to many broker-dealers and their registered representatives changing their business practice to a fee-based (advisory) model, which is often more expensive to clients over the long run.
• The proposal's bias towards an advisory model is due to, among other things, the overly broad and vague way the proposal addresses conflicts of interest; the requirement that covered persons make recommendations "without regard to the financial or other interest of any party other than the customer or client"; and the increased compliance costs and responsibilities that will result from the proposal's fiduciary duty and its ongoing obligations, thereby pushing firms to reduce consumer choice at an increased cost.
• Since most fee-only advisors have minimum asset requirements of $250,000, $500,000 or more, small and mid-level investors will lose access to financial products as well as the advice and services of financial professionals. Where will these consumers get needed advice and service from? Even if firms expand their offerings  consumers will now need to pay for an ongoing fiduciary obligation that they may not want or need to pay for.
• The proposal may also limit consumer choices on annuity and life insurance products.  The additional costs associated with complying with this regulation may ultimately reduce the performance of these products. 
• The Securities Division's proposal, alongside new rules from the SEC and potentially the Massachusetts  Insurance Division, will likely lead to overlapping, duplicative or conflicting requirements that could increase consumer confusion and result in serious compliance issues for advisors.

NAIFA has always been most concerned about giving our clients the best service and advice possible given each of our clients' particular situations.  As we all know there is no one strategy that works for every client and we support regulation that allows our clients to have a choice of both strategy and the method of receiving advice and accessing products that best fits their own needs.

 *The National Association of Insurance and Financial Advisors (NAIFA) Massachusetts over 470 members statewide who are licensed insurance agents and financial advisors who focus their practices on one or more of the following: long term care insurance, disability insurance, life insurance and annuities, health insurance and employee benefits, multiline, and financial advising and investments.

William H. Altman, LUTCF
Financial Representative
The Bulfinch Group

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Stephen Dembowski

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Stephen Dembowski
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Verner Khederian

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Verner Khederian
FlagshipHarbor Advisers

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: James Fuerstnau

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

James Fuerstnau
Financial Advisor
Ameriprise

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Bridget Grella

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Bridget Grella
LPL

Subject: Reconsider new provision to 950 CMR 12,200.
From: Theresa Yong

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Theresa Yong

Subject: Reconsider new provision to 950 CMR 12,200.
From: Mary Clausen

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,

Mary Clausen

Subject: Proposed Fiduciary Regulation
From: Joshua O’Gara

Dear Secretary Galvin,

I’m writing today to express my opposition to your proposed regulation regarding the fiduciary standard for the financial services industry in Massachusetts. Although I whole-heartedly agree with the objective to protect consumers in the Commonwealth, I believe this regulation goes too far and will ultimately limit choice for consumers and limit access to financial advice to the lower and middle income market. I do not hold a license to sell securities, however I am particularly concerned regarding the inclusion of insurance products in the proposed regulation.

In addition to my insurance practice, I also have been a long-time volunteer with the National Association of Insurance and Financial Advisors (NAIFA) and I currently serve on the board of directors as the State President. There are many other members of our association who share these concerns and we would be happy to have further conversations with your office about the potential adverse consequences of this regulation.

Thank you for your consideration,

Josh O’Gara CLU,ChFC, CFP®
Brokerage Consultant
CFG Brokerage Network

Subject: Reconsider new provision to 950 CMR 12,200.
From: Tracy Hendrickson

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,

Tracy Hendrickson

Subject: Reconsider new provision to 950 CMR 12,200.
From: Kerine Gordon

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,

Kerine Gordon

Subject: Reconsider new provision to 950 CMR 12,200.
From: John Borders

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
John Borders

Subject: Reconsider new provision to 950 CMR 12,200.
From: Andrew DeSimone

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Andrew DeSimone

Subject: Reconsider new provision to 950 CMR 12,200.
From: Andrew DeSimone

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Andrew DeSimone

Subject: Reconsider new provision to 950 CMR 12,200.
From: Kendrick Kester

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Kendrick Kester

Subject: Reconsider new provision to 950 CMR 12,200.
From: Vanessa Fuccione

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Vanessa Fuccione

Subject: Reconsider new provision to 950 CMR 12,200.
From: Steve Schoonveld

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Steve Schoonveld

Subject: Reconsider new provision to 950 CMR 12,200.
From: Andres Vilms

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Andres Vilms

Subject: Reconsider new provision to 950 CMR 12,200.
From: Adam Graham

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Adam Graham

Subject: Reconsider new provision to 950 CMR 12,200.
From: Laurel Soltys

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
laurel soltys

Subject: Reconsider new provision to 950 CMR 12,200.
From: Jeffrey Giovannelli

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Jeffrey Giovannelli

RE: Proposed Revisions to 950 CMR 12.200 (PDF)

Principle Concerns (PDF)

Subject: Reconsider new provision to 950 CMR 12,200.
From: Kelly Conroy

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Kelly Conroy

Subject: Reconsider new provision to 950 CMR 12,200.
From: Charlene Albanese

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Charlene Albanese

Subject: Reconsider new provision to 950 CMR 12,200.
From: Alison Stewart

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Alison Stewart

Life Insurance Association of Massachusetts (PDF)

Carol B. Seitz (PDF)

American Benefits Council (PDF)

Institute for Portfolio Alternatives (PDF)

VIA e-mail to: securitiesregs-comments@sec.state.ma.us

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

To whom it may concern:

I am a resident of Massachusetts and a long-time investor. I have worked with individual financial advisers for many years, and they have provided me with valuable assistance in managing my investments and providing for my financial future. My current adviser has offered me different services and methods of compensation, giving me the flexibility to choose the type of services I want and the most cost-effective way to pay for them.

The Secretary of the Commonwealth and the Massachusetts Securities Division have recently proposed new regulations that will make it more difficult for me to work with my financial adviser by favoring certain business models over others, restricting access to products and services that I find valuable, and increasing the cost of services provided by financial advisers in Massachusetts. I understand the need for regulation of financial advisers, and have generally agreed with the approach of the Securities Division in taking actions to protect investors like me.   However, the proposed regulations will create many more problems than they solve and will not benefit most investors.

The U.S. Securities and Exchange Commission has recently enacted regulations that would provide many of the same investor protections that the Securities Division is trying to create, and the regulations proposed by the Division will be in direct conflict with those of the SEC. Massachusetts is not an island. It is part of an interconnected universe of individual investors like me. If the Division enacts regulations that are inconsistent with those of the SEC and other states, many financial advisers will choose not to do business in Massachusetts, harming me and many people like me. This is not in the interest of either investors or the Massachusetts economy. I strongly suggest that the Securities Division avoid adoption of regulations that are inconsistent with those of the SEC, and wait until the effects of the new SEC rules can be understood and evaluated. I also request that the Division avoid taking any action that will reduce access to products and services that I and many other investors find valuable and would like to continue receiving.

Thank you for your consideration.

Kevin J. Cicci
East Walpole, MA

Subject: Reconsider new provision to 950 CMR 12,200.
From: Paul O'Glishen

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Paul O'Glishen

Subject: Reconsider new provision to 950 CMR 12,200.
From: Matt Smith

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Matt smith

Securities Industry and Financial Markets Association(PDF)

RE: Proposed Fiduciary Conduct Standard (PDF)

Consumer Federation of America (PDF)

Investment Adviser Association (PDF)

South Shore Chamber of Commerce (PDF)

Investment Company Institute (PDF)

UBS Financial Services (PDF)

Subject: Protect Consumer Choice and Retirement Savings!
From: Mark Teed

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Mark Teed
Branch Manager & Senior Vice President -Investments
Teed Capital Management Of Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Julie Frisoli

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Julie Frisoli
Vice President, Human Resource Business Partner
Ameriprise Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Michael Murray

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Murray
LPL Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Rose Labaky

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Rose Labaky
Senior Compliance Analyst
Columbia Threadneedle

Subject: Protect Consumer Choice and Retirement Savings!
From: Michael Serafino

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Serafino
Senior Vice President, Investments
Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Thomas McGuire

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Thomas McGuire
Chief Compliance Officer
Columbia Threadneedle

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Greg Pennini

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Greg Pennini
LPL Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Brian Wyman

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Brian Wyman
Financial Advisor Associate Vice President
Ameriprise Financial, Inc.

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Suzanne Levin

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Suzanne Levin
Bay Financial Associates

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Marc Garand

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Marc Garand
Associate Financial Planner
Ameriprise Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Richard Turner

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Richard Turner
LPL Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Tara Gately

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Tara Gately
Equity Analyst
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Patrick Devery

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Patrick Devery
Sr. Director, Asset Management Compliance
Ameriprise Financial, Inc.

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Joseph Reidy

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Joseph Reidy
Financial Advisor, Certified Financial Planner™ practitioner
Ameriprise Financial Services, Inc.
Boston College Alumni '71

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Vincent Petrangelo

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Vincent Petrangelo
FINANCIAL ADVISOR
AMERIPRISE

Subject: Protect Consumer Choice and Retirement Savings!
From: Lawrence Eppolito

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Lawrence Eppolito
President, Eppolito Financial Strategies, LLC
Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Brian O'Donnell

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Brian O'Donnell
Compliance Director
Columbia Threadneedle

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Annina Smith

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Annina Smith
IT Risk Senior Manager
Ameriprise

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Karen Busanovich

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration. Karen Busanovich LPL Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Wendy Karkoska

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Wendy Karkoska
Sales Associate Alex Brown,
Raymond James

Subject: Protect Consumer Choice and Retirement Savings!
From: Jay Murphy

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jay Murphy
Director - Client Advisor
Alex Brown - Division of Raymond James

Subject: Protect Consumer Choice and Retirement Savings!
From: Roberto Solano

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Roberto Solano
Managing Director
Steward Partners and Raymond James

Subject: Protect Consumer Choice and Retirement Savings!
From: John Postizzi

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

John Postizzi
Financial Advisor
Raymond James

Subject: Protect Consumer Choice and Retirement Savings!
From: Ryan Hendrickson

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Ryan Hendrickson
President and Financial Advisor
Raymond James Financial Services

Subject: Protect Consumer Choice and Retirement Savings!
From: Jason Tholander

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jason Tholander
Branch Manager, Financial Advisor
Raymond James Financial Services

Subject: Protect Consumer Choice and Retirement Savings!
From: Eric Bergstrom

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Eric Bergstrom
Financial Advisor
Raymond James Financial Services (FID)

Subject: Protect Consumer Choice and Retirement Savings!
From: Phillip Closuit

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Phillip Closuit
Senior Vice President, Investments
Raymond James

Subject: Protect Consumer Choice and Retirement Savings!
From: Daniel Rabatsky

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Daniel rabatsky
Financial Advisor
Raymond James

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Paul Schofield

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Paul Schofield
Schofield Financial Services/LPL Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: John Mcdonough

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

John Mcdonough
Financial advisor
Raymond James advisors

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Alexander Kezer

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Alexander Kezer
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Christopher Moschella

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Christopher Moschella
Financial Advisor
Ameriprise Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: David Clark

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

David Clark
Managing Director
Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Stephen Buff

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Stephen Buff
Chief Compliance Officer
ColumbiaThreadneedle Investments

Subject: Protect Consumer Choice and Retirement Savings!
From: Matthew Davis

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Matthew Davis
Financial Advisor
Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Vincent Panzini

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Vincent Panzini
Financial Advisor
Ameriprise

Subject: Protect Consumer Choice and Retirement Savings!
From: Peter Frisch

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Peter Frisch
Partner Managing Director – Wealth Manager
Steward Partners Global Advisory and Ray James Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Samuel Chamberlain

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors’ access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients’ access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Samuel Chamberlain
Executive V & Financial Advisor
Boston Harbor Wealth Advisors, LLC/Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Carolyn Nolan

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Carolyn Nolan
CFP Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Thomas Pedersen

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Thomas Pedersen
financial planner Ameriprise Financial, Inc

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Richard Byrd

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors’ access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients’ access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Richard Byrd
managing director financial advisor
Raymond james and associates

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Kevin Sullivan

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that’s dedicated to helping millions of individual and small business clients reach their financial goals. I’m writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients’ interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Kevin Sullivan
Sr.Compliance Manager/Certified Anti-Money Laundering Specialist
Ameriprise Financial/Columbia Threadneedle Investments

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Christopher Ronkese

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients’ access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients’ interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Christopher Ronkese
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Harold Wiksten

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients’ access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients’ interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Harold Wiksten
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Gary Oman

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients’ access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients’ interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Gary Oman
U.S. Wealth Management

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Bharathan Ilangovan

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that’s dedicated to helping millions of individual and small business clients reach their financial goals. I’m writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients’ interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Bharathan Ilangovan
Vice President
Ameriprise Financial Inc

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Bharathan Ilangovan

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that’s dedicated to helping millions of individual and small business clients reach their financial goals. I’m writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients’ interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Bharathan Ilangovan
Vice President
Ameriprise Financial Inc

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Neal Borges

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Neal Borges CFP CLU ChFC
Financial Advisor | Managing Director
Ameriprise Financial Services, Inc.

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Corey Scrupps

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients’ access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients’ interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Corey Scrupps
LPL Financial

Subject: Your voice matters – Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Eileen Simons

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that’s dedicated to helping millions of individual and small business clients reach their financial goals. I’m writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients’ interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Eileen Simons
Senior Compliance Manager
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Nicholas Cantone

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that’s dedicated to helping millions of individual and small business clients reach their financial goals. I’m writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients’ interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Nicholas Cantone
Regional Director - Business. Development
Ameriprise Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: James Hoogasian

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients’ access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients’ interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

James Hoogasian LPL

January 6, 2020 – Greig Rance

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: James Hoogasian

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that’s dedicated to helping millions of individual and small business clients reach their financial goals. I’m writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients’ interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Greig Rance
Vice President Ameriprise

Subject: Protect Consumer Choice and Retirement Savings!
From: Paul Lisanke

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors’ access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients’ access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Paul Lisanke Director
Alex. Brown

Subject: Protect Consumer Choice and Retirement Savings!
From: Daniel Ryan

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors’ access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients’ access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Daniel Ryan
Client Advisor
Raymond James Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Janet Frye

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors’ access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients’ access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Janet Frye
Senior Vice President,
1776 Financial RJFS,
Raymond James Raymond James

Subject: Protect Consumer Choice and Retirement Savings!
From: Stephen Kelleher

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors’ access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients’ access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Stephen Kelleher
Vice President
Raymond James (I work at Alex Brown which is a division of Raymond James)

Subject: Protect Consumer Choice and Retirement Savings!
From: Michael Garrison

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors’ access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients’ access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Garrison
CEO Garrison Financial Inc, CFP, ChFC
Raymond James Financial Services, Inc

Subject: Protect Consumer Choice and Retirement Savings!
From: Henry Shaughnessy

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors’ access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients’ access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Henry Shaughnessy
Sr. Advisor-Supervision
Raymond James Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Patricia Beckwith

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors’ access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients’ access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Patricia Beckwith
Branch Manager
Raymond James Financial Services

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Melissa Indelicato

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Melissa Indelicato
Private Wealth Advisor
Ameriprise

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Melissa Indelicato

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Melissa Indelicato
Private Wealth Advisor
Ameriprise

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Jacob Larson

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jacob Larson
Associate financial advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Leilani Germain

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Leilani Germain
Associate Vice President
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Leilani Germain

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Leilani Germain
Associate Vice President
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Stephen Adams

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Stephen Adams
Financial Advisor
Ameriprise

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Rich Van Loan

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Rich Van Loan
Private Wealth Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Catherine Fitzgerald

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Catherine Fitzgerald
Financial Advisor
Ameriprise Financial Advisors

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Michael Alimi

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Alimi
Private Wealth Advisor
Vice President Ameriprise Financial

Subject: Reconsider new provision to 950 CMR 12,200.
From: Michael Prestielo

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Michael Prestileo

Insured Retirement Institute (PDF)

Chamber of Commerce.pdf (PDF)

Subject: Reconsider new provision to 950 CMR 12,200.
From: Lauren Gawlik

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Lauren Gawlik

Subject: Reconsider new provision to 950 CMR 12,200.
From: Beth Griffith

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Beth Griffith

Subject: Reconsider new provision to 950 CMR 12,200.
From: Kevin FLynn

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Kevin FLynn

Subject: Reconsider new provision to 950 CMR 12,200.
From: Erin Miner

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Erin Miner

Massachusetts Taxpayers Foundation (PDF)

Financial Services Institute (PDF)

Subject: Reconsider new provision to 950 CMR 12,200.
From: Francis W. Farley

272 Willow Ave.
Somerville, MA 02144
Jan. 7, 2020

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

To whom it may concern:
I am a resident of Massachusetts and a long-time investor. I have worked with individual financial advisers for many years, and they have provided me with valuable assistance in managing my investments and providing for my financial future. My current adviser has offered me different services and methods of compensation, giving me the flexibility to choose the type of services I want and the most cost-effective way to pay for them.

The Secretary of the Commonwealth and the Massachusetts Securities Division have recently proposed new regulations that will make it more difficult for me to work with my financial adviser by favoring certain business models over others, restricting access to products and services that I find valuable, and increasing the cost of services provided by financial advisers in Massachusetts. I understand the need for regulation of financial advisers, and have generally agreed with the approach of the Securities Division in taking actions to protect investors like me. However, the proposed regulations will create many more problems than they solve and will not benefit most investors.

The U.S. Securities and Exchange Commission has recently enacted regulations that would provide many of the same investor protections that the Securities Division is trying to create, and the regulations proposed by the Division will be in direct conflict with those of the SEC. Massachusetts is not an island. It is part of an interconnected universe of individual investors like me. If the Division enacts regulations that are inconsistent with those of the SEC and other states, many financial advisers will choose not to do business in Massachusetts, harming me and many people like me. This is not in the interest of either investors or the Massachusetts economy.  For years, my adviser/broker has offered me advice concerning investments, but I have made my own decisions regarding the purchase and sale of securities in my investment portfolio.  It dismays me to contemplate that this situation, which has benefited me for years, may be about to end.  This is not progress.

I strongly suggest that the Securities Division avoid adoption of regulations that are inconsistent with those of the SEC, and wait until the effects of the new SEC rules can be understood and evaluated. I also request that the Division avoid taking any action that will reduce access to products and services that I and many other investors find valuable and would like to continue receiving.

I thank you for your time and consideration in this matter.

Sincerely,
Francis W. Farley

American Securities Association (PDF)

New York Life Insurance Company (PDF)

Pacific Life Insurance Company (PDF)

North American Securities Administrators Association (PDF)

Alison Jones (PDF)

Massachusetts Mutual Life Insurance Company & MML Investors Services (PDF)

Kurt Jamiel (PDF)

Morgan Stanley Smith Barney (PDF)

American Retirement Association (PDF)

CUNA Mutual Group (PDF)

Massachusetts Business Roundtable (PDF)

Public Investors Advocate Bar Association (PDF)

Fidelity Investments (PDF)

Primerica, Inc. & Various Agents of PFS Investments Inc. (PDF)

Associated Industries of Massachusetts (PDF)

AARP (PDF)

Charles Schwab & Co. (PDF)

Subject: regulation
From: laucfp@comcast.net

VIA e-mail to: securitiesregs-comments@sec.state.ma.us

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

To whom it may concern:

I am a resident of Massachusetts and a long-time investor. I have worked with individual financial advisers for many years, and they have provided me with valuable assistance in managing my investments and providing for my financial future. My current adviser has offered me different services and methods of compensation, giving me the flexibility to choose the type of services I want and the most cost-effective way to pay for them.

The Secretary of the Commonwealth and the Massachusetts Securities Division have recently proposed new regulations that will make it more difficult for me to work with my financial adviser by favoring certain business models over others, restricting access to products and services that I find valuable, and increasing the cost of services provided by financial advisers in Massachusetts. I understand the need for regulation of financial advisers, and have generally agreed with the approach of the Securities Division in taking actions to protect investors like me.   However, the proposed regulations will create many more problems than they solve and will not benefit most investors.

The U.S. Securities and Exchange Commission has recently enacted regulations that would provide many of the same investor protections that the Securities Division is trying to create, and the regulations proposed by the Division will be in direct conflict with those of the SEC. Massachusetts is not an island. It is part of an interconnected universe of individual investors like me. If the Division enacts regulations that are inconsistent with those of the SEC and other states, many financial advisers will choose not to do business in Massachusetts, harming me and many people like me. This is not in the interest of either investors or the Massachusetts economy. I strongly suggest that the Securities Division avoid adoption of regulations that are inconsistent with those of the SEC, and wait until the effects of the new SEC rules can be understood and evaluated. I also request that the Division avoid taking any action that will reduce access to products and services that I and many other investors find valuable and would like to continue receiving.

Thank you for your consideration.

Greater Boston Chamber of Commerce (PDF)

Subject: XYPN Public Comment Letter on Fiduciary Proposal
From: XY Planning Network

RE: Solicitation of Public Comments regarding Proposed Fiduciary Conduct Standard

Dear Secretary Galvin:

We are writing to voice support for the Massachusetts Securities Division (MSD) proposal regarding a fiduciary standard for all investment advice provided in the state of Massachusetts, whether delivered from a registered investment adviser, broker-dealer, or insurance agent, when they are acting in (or would reasonably be expected to be acting in) the capacity of a 'financial advisor'.

We represent XY Planning Network, which provides business support services over 1,100 advisor members currently providing fiduciary financial planning advice as Registered Investment Advisers in states across the country. All of our members currently operate solely as fiduciaries, registered solely as investment advisers. Our focus is to provide fiduciary financial planning advice to Gen X and Gen Y consumers, without any asset minimums and without any product sales (as all of our members are Fee-Only, and none of our members are FINRA-registered).

At XYPN, we believe that all financial advice should be delivered under a fiduciary standard, as the very essence of what it means to provide "advice" is to provide "guidance or recommendations offered with regard to prudent future action", which inherently is framed as the appropriate future action for the recipient of the advice (i.e., in their best interests). Thus, when the Supreme Court enshrined a fiduciary duty for Registered Investment Advisers in the case of SEC vs. Capital Gains Research Bureau, it acknowledged that "the [Investment Advisers Act of 1940], in recognition of the adviser's fiduciary relationship to his client, requires that his advice be disinterested."

Accordingly, we support the newly proposed MSD standard to apply a fiduciary duty to all advice, whether provided by an RIA, a broker-dealer, or an insurance agent when acting in the capacity of providing advice (even in the situation where non-securities annuity products as sold, to the extent they entail the sale of a securities product or the liquidation of a securities account in order to purchase such a non-securities product).

However, we believe and recognize that broker-dealers to play a vital function in the capital formation process, and the ability to investors to access and participate in (secondary) capital markets, as well as the broader distribution of financial services products (alongside insurance/annuity agents), which are inherently sales and not advice-based fiduciary functions.

As a result, while we applaud MSD's action to apply a uniform fiduciary standard to financial advice delivered by RIAs, broker-dealers, and insurance agents, we do not believe that it is appropriate to apply a uniform fiduciary standard to all RIA and broker-dealer (and insurance/annuity agents) entities operating in the state of Massachusetts, which risks impairing the important roles that broker-dealers and insurance/annuity agents play in non-advice sales functions for consumers who simply want to purchase a product.

Accordingly, we have concern that the MSD approach does not go far enough in clearly establishing a bright-line division between where sales activity ends and advice activity begins. While certain tests that MSD establishes are effective – such as applying the standard to those who hold out using titles that convey an advice relationship, those who exercise discretion in client accounts, and those who receive ongoing compensation for ongoing advice – we remain concerned about whether MSD sufficiently separates bona fide episodic advice from episodic sales transactions that may unwittingly convey a 'recommendation' to purchase the product in the sales process.

Adopting The 'Solely Incidental' Exemption Of The Investment Advisers Act Of 1940 To Separate Sales From Advice And Promote Regulatory Uniformity
At the Federal level, the core framework of the separation between brokers and investment advisers – and the separation of sales from advice – dates back to the origin of the Investment Advisers Act of 1940, which occurred after the Securities Exchange Act of 1934, and specifically created a new class of (registered) investment advisers to whom additional and higher standards of care would apply, and from which only a delineated segment of broker-dealers may be carved out.

Specifically, the '40 Act declared that an investment adviser included:
"…any person who, for compensation, engages in the business of advising others, either directly or through publications or writings, as to …the advisability of investing in, purchasing, or selling securities…․"

In turn, to ensure that consumers still have the choice of engaging with an investment adviser or a broker-dealer, Congress specifically carved out the Section 202(a)(11)(C) exception for broker-dealers, stating that the "investment adviser" term did not include:
"…any broker or dealer whose performance of such services is solely incidental to the conduct of his business as a broker or dealer and who receives no special compensation therefor…" (emphasis mine)

The Merriam-Webster dictionary defines "incidental" as:
1) being likely to ensue as a chance or minor consequence; or
2) occurring merely by chance or without intention or calculation
In this context, "solely incidental" advice would constitute advice that occurs either: a) by chance; b) as a consequence of product sales (i.e., that the sale would precede the advice, and not the other way around, such that the advice was a consequence and not an antecedent); or c) without intent to give advice.

We believe this delineation of sales versus advice by exempting advice that is "solely incidental" to the sale of brokerage (or insurance) products remains a reasonable regulatory approach to separate sales from advice. Unfortunately, in practice we believe the SEC has been lax in enforcing this standard (see https://www.kitces.com/blog/is-the-sec-failing-to-enforce-the-solely-incidental-advice-exemption-for-broker-dealers-under-the-investment-advisers-act-of-1940/), both with respect to the SEC's unwillingness to recognize that when a broker-dealer holds out as an advisor that they are clearly establishing a more-than-solely-incidental-advice relationship (which MSD's proposed fiduciary rule would address), and that the SEC has unreasonably expanded the scope of "solely incidental" itself to the point that virtually all broker-dealer-based advice activity would be sheltered under the exemption as long as a brokerage product were sold at the end (and thus why XYPN has filed suit against the SEC's Regulation Best Interest).

Accordingly, we suggest that MSD should look to adopt a similar "solely incidental" exemption for non-advice brokerage (or insurance sales) activities, to assist in the delineation of purely brokerage or insurance sales activity from advice, but interpret the "solely incidental" line stringently with respect to both titles and holding out (and advice-oriented designations like CFP certification used for marketing purposes), whether any level of financial planning services are offered (which inherently create an expectation of advice), or whether a financial plan is delivered.

The SEC's guidance in its 2005 rule "Certain Broker-Dealers Deemed Not To Be Investment Advisers" provides a viable template for this approach, when the SEC stated:
"…when a broker-dealer provides advice as part of a financial plan or in connection with providing planning services, a broker-dealer provides advice that is not solely incidental if it: (i) holds itself out to the public as a financial planner or as providing financial planning services; or (ii) delivers to its customer a financial plan; or (iii) represents to the customer that the advice is provided as part of a financial plan or financial planning services…"

An added benefit of this approach in conforming MSD's exemption for purely-sales activity of broker-dealers and insurance agents to the "solely incidental" exemption of the Investment Advisers Act of 1940 is that it better supports state-Federal conformity, and makes it easier for other states to adopt similar confirming rules. As MSD would still have the latitude to enforce its solely incidental exemption in a more stringent manner than the SEC has in the past, while still permitting brokers and insurance agents to simply be brokers and insurance agents.

No Need To Delay – Fiduciary Regulation Of Advice Will Not Limit Consumer Access To Advice In Massachusetts
While certain detractors of various state (and Federal) fiduciary proposals have raised concerns that a fiduciary duty will make it 'impossible' to do business in the state, and/or that Massachusetts (or other states') consumers will lose access to financial advice, we feel it is crucial to point out that XY Planning Network has quickly grown over just the past 5 years to a network of more than 1,100 advisors, all of whom operate fully and solely under a fiduciary standard with a particular focus on Gen X and Gen Y consumers, and do so without any asset minimums or product sales. Instead, XYPN members simply charge a financial planning fee for services rendered. 

In other words, XY Planning Network has already actively demonstrated that it is feasible to serve the marketplace under a fiduciary standard, without asset minimums or product sales, simply by making fiduciary financial advice available to anyone who is ready to pay a professional for such advice. While some brokerage firms may suggest that it is not feasible to deliver advice to the middle market cost effectively, we are living proof – at a scale that already nears the size of a top-30 broker-dealer by advisor headcount, and growing at a pace of more than 40 new advisors per month. 

In addition, we are living proof, at more than 1,100 advisors of scale and growing rapidly, to reject the notion that imposing a fiduciary standard creates untenable liability for advice professionals serving Massachusetts consumers. In fact, XYPN provides Errors & Omissions insurance directly to the majority of our members, and in 5 years have never had a single claim filed in any year against any member. And as a result of the extremely low litigation risk of fiduciary advice, E&O underwriters are able to price such insurance for our members at less than $100/month, far cheaper than typical E&O coverage at broker-dealers (whose claims rates are likely higher because of the attempt to deliver conflicted advice instead of fiduciary advice).

In other words, fiduciary advice to the middle market doesn't have to be prohibitively expensive; instead, we have demonstrated in practice that it can be delivered cost effectively, and when done with our high XYPN standards (including a ban on advisors with a problematic regulatory history, and a requirement of at least 3 years of experience and CFP certification before holding out to the public as an XYPN member), results in lower E&O insurance costs and legal liability contingencies to deliver fiduciary advice than the typical conflicted-advice brokerage model today. In other words, a fiduciary rule can actually lower the cost of advice, while also raising standards for Massachusetts investors.

Consequently, to the extent that brokerage firms and other opponents of the Massachusetts fiduciary proposal have suggested that they may abandon the state and/or find it untenable to serve Massachusetts consumers when held to such a standard, organizations like XY Planning Network and its more-than-1,100+ advisors stand ready to serve Massachusetts consumers and provide investment advice on a fiduciary basis under the rule as proposed, without investment minimums or conflicted product sales.

Similarly, we do not believe that MSD should wait for the SEC's Regulation Best Interest to be implemented – both because we have actively challenged Regulation Best Interest and asked the courts to vacate the rule for violating Congressional mandates under both the Dodd-Frank Act of 2010 and the Investment Advisers Act of 1940 – but because the non-fiduciary standard that Reg BI creates for broker-dealer advice undermines consumer trust in financial services and fails to adhere advice to the natural (fiduciary) standard to which all advice has always been held under law.

Still, though, we do believe that consumers deserve a choice – between a salesperson or an advisor – and that Regulation Best Interest actually is an appropriate standard for (brokerage) salespeople (operating purely in a sales capacity), while a fiduciary rule is best for anyone who provides advice (or holds out and implies an advice relationship).

And so while we strongly urge Massachusetts to move forward with a fiduciary rule, we do suggest that broker-dealers be allowed to continue to provide brokerage-only services (and insurance agents be permitted to continue to provide annuity-product-only services), as long as their marketing clearly conveys the limited non-advice scope of their services, and their actual advice does not include financial planning services or the delivery of a financial plan. To the extent that still results in any broker-dealers or insurance agents leaving Massachusetts, XYPN's substantial and growing base of advisors are ready and willing to provide fiduciary advice to Massachusetts consumers in their absence.

Respectfully,
- Michael Kitces, Co-Founder, XY Planning Network
- Travis Johnson, Director of Compliance, XY Planning Network

The Northwestern Mutual Life Insurance Company (PDF)

Subject: Reconsider new provision to 950 CMR 12,200.
From: Chelsea Macfarlane

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
chelsea macfarlane

Association for Advanced Life Underwriting (PDF)

Governor Charles D. Baker (PDF)

LPL Financial (PDF)

Raymond James Financial (PDF)

Lincoln Financial Group (PDF)

State Street Global Advisors (PDF)

Subject: Reconsider new provision to 950 CMR 12,200.
From: Dianne Eyssallenne

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Dianne Eyssallenne

Capital Group (PDF)

Cetera Financial Group (PDF)

Financial Planning Association (PDF)

Complaint

Massachusetts Bankers Association (PDF)

RBC Capital Markets (PDF)

Institute for the Fiduciary Standard(PDF)

Massachusetts Competitive Partnership (PDF)

Subject: 950 CMR
From: Kris Cloyd

In reviewing the  changes you want to make regarding 950 CMR, I submit the following:

1. Please define what you mean by the term Fiduciary Duty and how it applies to securities transactions.  This is unclear in the legislation and I'd like examples of how this would apply as you see it.
2. In 950 CMR 12.207 2 (b) 2, you frequently mention Conflicts of Interest.  Again, please define how you interpret what is and what isn't a conflict of interest.

It appears to me you are trying to eliminate the sale of investments where the rep makes a commission.  This would mean you want all reps to sell products that have a monthly, quarterly or annual fee to the client.  I firmly believe this is the worst way to treat most clients and the best way to increase the compensation of the reps.  This, I believe, is the exact opposite you want to accomplish!

Here's a recent example:  A long-term client inherited a IRA from his father.  This account had $2.8 million in it.  If he invested $1.4 million into each of two mutual fund families, he would have been able to purchase these accounts with a zero up front cost.  The annual fees would be between 0.5% and1.0% with a 0.25% trail commission to the rep (which is included in the annual fees).  On the other hand, if this was put into a fee brokerage account, where the rep charges 1% as his/her fee, plus the management cost of 0.5 – 1.0%, the client would be paying an extra $28,000 a year in fees.  Assuming no growth or withdrawals in the account, this would cost the client $280,000 extra over 10 years.  Is this really in the client's best interest?  Absolutely not, but your legislation seems to be pushing reps in that direction.

Another example:  A client has a 401k rollover with $100,000 in it.  Most fund companies have lower sales loads at this breakpoint.  If you put this money say in the American Funds, the client would pay a 3.5% sales charge.  Would it be better off for the client to pay 3.5% one time or to pay 1% a year for 10, 20, or more years?  Clearly, clients would choose to pay the 3.5% fee once.  Why are you pushing us to have the client pay far more in fees?

This is really good for the reps, but terrible for the clients.  Please take another looks at your legislation and make sure you are doing what's right for clients.

Kris Cloyd, CFP
Cloyd Financial Planning

Commonwealth Financial Network (PDF)

Subject: Protect Consumer Choice and Retirement Savings!
From: Marc Orloff

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Marc Orloff FA
Raymond James

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Alexander DaCunha

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Alexander DaCunha
Webster Investment Services

Subject: Protect Consumer Choice and Retirement Savings!
From: Charles Bonatakis

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Charles Bonatakis
Senior Vice President
Raymond James

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Timothy Nolan

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Timothy Nolan
Financial Advisor, Managing Director
Ameriprise Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Michael Berardi

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Berardi
Bay Financial Associates

Subject: Protect Consumer Choice and Retirement Savings!
From: George Puliafico

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

George Puliafico
Branch Manager Raymond James Financial
Raymond James Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Timothy Davis

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors' access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients' access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Timothy Davis
Financial Advisor & Certified Financial Planner
Steward Partners

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Ryan McSheffrey

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Ryan McSheffrey
LPL

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Hiten Mehta

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Hiten Mehta
Financial advisor.
Ameriprise Financial.

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: John Rogers

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

John Rogers
Financial Advisor, CFP
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Michael Costa

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they've envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC's new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Michael Costa Michael Costa, CFP, CRPC, APMA
Ameriprise

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: David Vancil

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

David Vancil
Certified Financial Planner Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Michael Tempesta

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that’s dedicated to helping millions of individual and small business clients reach their financial goals. I’m writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients’ interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Michael Tempesta
Senior Director
Distribution / Anti-Money Laundering Compliance Columbia Threadneedle

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: John Castelot

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients’ access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients’ interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

John Castelot
LPL Financial, LLC

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Wayne E. Cook

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients’ access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients’ interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Wayne E. Cook
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: DawnMarie Corneau

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients’ access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients’ interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

DawnMarie Corneau
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Robert Danna

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients’ access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients’ interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Robert Danna LPL

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Linda Gallant

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Linda Gallant
Paraplanner Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Suzanne Regan

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Suzanne Regan
Financial Planning Specialist
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Lindsay Dyment

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Lindsay Dyment
Admin
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Karen Newman

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that's dedicated to helping millions of individual and small business clients reach their financial goals. I'm writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients' interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Karen Newman
Marketing manager
Ameriprise/Columbia Threadneedle Investments

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Louis Curto

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Louis Curto
LPL Financial

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Stanley Fanfan

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients' interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Stanley Fanfan
Webster Bank

Subject: Your voice matters - Massachusetts is implementing a proposal that would reduce choice access to savings advice
From: Nancy Martin

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts, and work hard on behalf of my clients to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college and funding retirement. I am concerned that your recently released proposal to create a state-specific fiduciary standard for financial representatives will limit investors’ access to professional financial guidance, products and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact your proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but individuals as well. This limitation on investor choice will force middle income savers to decide between moving to accounts that may not suit their needs or preferences, and going at it alone without personal assistance from a licensed financial professional. As a result, investors will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard adopted by the Securities and Exchange Commission, which creates a uniform best interest standard across the entire retail marketplace and preserves my clients’ access to current products and services. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Nancy Martin
Sales Assistant Raymond James & Associates

Subject: Reconsider new provision to 950 CMR 12,200.
From: Salvatore Sigleski

Dear Secretary Galvin,

As a resident of the Commonwealth, I am writing to urge you to reconsider the proposed regulation on the fiduciary standard of conduct for broker-dealers, agents and investment advisers. The proposed regulation will be a barrier to retirement savers like me by placing undue burdens on how I can receive and pay for financial advice.

The proposal will also have a significant impact on life insurers and those financial professionals who offer important insurance products, including retirement products that guarantee a lifetime stream of income. At a time when financial guidance is critical, this regulation will limit the ability of those who need it the most to get the information and affordable advice they need.

I respectfully request that this proposed regulation be modified to ensure that all residents of the Commonwealth are able to receive the important financial guidance they need to have a secure retirement.

Sincerely,
Salvatore Sigleski

Subject: Proposed MA Securities Regulation Best Interest
From: Paul DeSimone

Dear Secretary Galvin,

Notwithstanding these comments are being submitted after the Public Hearing on January 7, 2020, I wanted to enter a perspective for the record.

My comments below are informed by over 30 years as a FINRA-registered Principal, who has had varied executive responsibilities with Broker/Dealers and Investment Advisors, including considerable exposure to the Compliance Functions of such firms.

Best Interest

Reacting to Governor Baker's disagreement with the proposed Regulation, apparently based in part on a belief that individual investors would be "deprived" of investment opportunities:

(1) the financial services, retirement and insurance industry nationally has demonstrated - for decades - an ability to adapt products and develop new investment products that conform with regulations.

(2) the notion of "deprivation of investment products" is not about the consumer, it is about the commission and fee paid advisory industry being deprived of selling products, and earning enormous incomes, to which they are accustomed.  

(3) during an interim period after adoption of the regulation, the manufacturers of products such as ETFs, fixed and variable and fixed indexed annuities, target date funds, mutual funds and the like are going to have their "product development" people and attorneys retro-fit investment options for consumers, to be offered on terms that comport with commission-based brokers and fee-based advisors, and the new Regulation.

(4) during an interim period after adoption of the regulation, the product development cycle will move forward with speed and deliberation, and any time that passes will not have a material effect on the retirement or financial solvency of any consumer or household - alternative products will be introduced very quickly for the consumer and retiree.  

I hope that the Commonwealth regulation does not go the way of the SEC's ineffective Best Interest rule.

Thank you.

P. DeSimone

Subject: Proposed New Regulations
From: Cindy Sullivan

January 9, 2020

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

To Whom It May Concern:

I am a resident of Massachusetts and a long-time investor. I have worked with individual financial advisers for many years, and they have provided me with valuable assistance in managing my investments and providing for my financial future. My current adviser has offered me different services and methods of compensation, giving me the flexibility to choose the type of services I want and the most cost-effective way to pay for them.

The Secretary of the Commonwealth and the Massachusetts Securities Division have recently proposed new regulations that will make it more difficult for me to work with my financial adviser by favoring certain business models over others, restricting access to products and services that I find valuable, and increasing the cost of services provided by financial advisers in Massachusetts. I understand the need for regulation of financial advisers, and have generally agreed with the approach of the Securities Division in taking actions to protect investors like me.   However, the proposed regulations will create many more problems than they solve and will not benefit most investors.

The U.S. Securities and Exchange Commission has recently enacted regulations that would provide many of the same investor protections that the Securities Division is trying to create, and the regulations proposed by the Division will be in direct conflict with those of the SEC. Massachusetts is not an island. It is part of an interconnected universe of individual investors like me. If the Division enacts regulations that are inconsistent with those of the SEC and other states, many financial advisers will choose not to do business in Massachusetts, harming me and many people like me. This is not in the interest of either investors or the Massachusetts economy. I strongly suggest that the Securities Division avoid adoption of regulations that are inconsistent with those of the SEC, and wait until the effects of the new SEC rules can be understood and evaluated. I also request that the Division avoid taking any action that will reduce access to products and services that I and many other investors find valuable and would like to continue receiving.

Thank you for your consideration.

Cindy Sullivan

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Scott Davis

Dear Secretary Galvin: I am a constituent in Massachusetts and am employed by a financial services firm that’s dedicated to helping millions of individual and small business clients reach their financial goals. I’m writing to express my deep concerns about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products and services and unnecessarily raising costs. Our financial professionals help clients prepare for major life events such as buying a home, sending kids to college, and funding retirement. These professionals already work in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure they put their clients’ interests first. The proposal will place costly and burdensome new requirements on financial professionals, and I believe that will increase costs for consumers and could cause investors to lose access to cost-effective brokerage accounts. Our clients deserve better. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. Thank you for your consideration.

Scott Davis
Vice President
Columbia Threadneedle Investments

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: John Worcester

Dear Secretary Galvin: I am a constituent and a licensed financial professional in Massachusetts. I work hard every day to help my clients successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. At a time when there is an urgent need for Americans to seek the kind of advice I offer, I take great pride in my work and in helping my clients take control of their finances and live the lives they’ve envisioned for themselves. I do this in compliance with multiple regulatory bodies, including the SEC, FINRA and state insurance departments, which ensure I meet my obligations to my clients and put their interests first. I am writing because I am concerned about the unintended consequences of your recently released proposal to create a state-specific fiduciary standard for financial professionals. Rather than paving the way for the citizens of Massachusetts to plan and save for their financial future, I believe it will make it harder for the average investor to do so by limiting access to professional advice, products, and services and unnecessarily raising costs with no corresponding investor benefit. The proposal will, among other things, require me to provide economically unsustainable monitoring services for brokerage accounts and satisfy an unworkable and vague conflicts requirement, both of which are in direct conflict with the SEC’s new strong holistic best interest standard. The cost of these requirements will result in the everyday investor losing access to cost-effective brokerage accounts. This limitation on investor choice will force middle-income consumers to decide between moving to accounts that may not suit their needs and preferences or going it alone without the help of a licensed financial professional. As a result, consumers will not be able to choose what works best for them. I urge you to reconsider your rule proposal and its unintended consequences for Massachusetts investors. It is imperative that consumer choice be protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

John Worcester
Financial Advisor
Ameriprise Financial

Subject: Public Comment for Massachusetts Fiduciary Proposal
From: Matthew O'Connor

Dear Acting Director Young-Spitzer: I am a licensed financial professional in Massachusetts. I work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that your recently released proposal to create a state specific fiduciary standard for financial representatives will limit clients’ access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. Brokerage accounts represent an important choice for consumers and provide access to affordable advice, particularly for buy-and-hold investors and for investors with more modest resources. I have concerns about the impact your proposal will have on small savers and investors. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts in situations when an investor prefers to pay for and receive advice on a transaction-by-transaction basis. I believe this proposal could result in the everyday investor losing access to cost-effective brokerage accounts. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. Over time, the rule proposal will likely result in a shift from brokerage accounts to fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact Massachusetts small businesses and their business models, but savers and investors. This limitation on investor choice could force many savers to decide between either advisory accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, small savers and investors would not be able to choose what works best for them. I put the best interests of my clients first every day and believe the recently established Regulation Best Interest standard significantly preserves and protects my clients’ interests and access to current products and services. I urge you to reconsider your rule proposal and its potential unintended consequences for Massachusetts investors and consumers. It is imperative consumer choice is protected and that no investor loses access to services critical to their financial stability, future goals or life planning. Thank you for your consideration.

Matthew O'Connor
LPL Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Jason Symond

Dear Sen. Boncore, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jason Symond
Wealth Management UBS

Subject: Protect Consumer Choice and Retirement Savings!
From: Brian Lynch

Dear Sen. Rausch, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Brian Lynch
Vice President UBS

Subject: Protect Consumer Choice and Retirement Savings!
From: Robert Salamy

Dear Sen. Seveney, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Robert Salamy
Senior VP Wealth Management UBS

Subject: Protect Consumer Choice and Retirement Savings!
From: Thaddeus Wiesehahn

Dear Sen. Keenan, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Thaddeus Wiesehahn
Financial Advisor - Vice President UBS

Subject: Protect Consumer Choice and Retirement Savings!
From: Camille Valentine

Dear Sen. DiDomenico, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Camille Valentine
Senior Vice President - Wealth Management UBS Financial Services Inc.

Subject: Protect Consumer Choice and Retirement Savings!
From: Erik Holton

Dear Sen. Boncore, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Erik Holton
Financial Advisor UBS Financial Services

Subject: Protect Consumer Choice and Retirement Savings!
From: Ian MacNeill

Dear Sen. Rausch, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Ian MacNeill
Branch Manager UBS

Subject: Protect Consumer Choice and Retirement Savings!
From: Daniel Lewin

Dear Sen. Boncore, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Daniel Lewin
Wealth Advisor UBS Financial.

Subject: Protect Consumer Choice and Retirement Savings!
From: Joseph Drier

Dear Sen. Brady, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Joseph Drier
Certified Financial Planner, Certified Private Wealth Advisor, Certified Exit Planning Advisor UBS

Subject: Protect Consumer Choice and Retirement Savings!
From: Jeffrey Swett

Dear Whip O'Connor, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Jeffrey Swett
Managing Director- Wealth Management UBS

Subject: Protect Consumer Choice and Retirement Savings!
From: Tim Chapin

Dear Rep. Vieira, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Tim Chapin
Senior Vice President - Wealth Management UBS Financial Services

Subject: Protect Consumer Choice and Retirement Savings!
From: William Todd

Dear Sen. Cyr, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

William Todd
Wealth Advisor UBS Financial

Subject: Protect Consumer Choice and Retirement Savings!
From: Matthew Goward

Dear Rep. Hunt, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Matthew Goward
Senior Wealth Strategy Associate UBS

Subject: Protect Consumer Choice and Retirement Savings!
From: Devin Callinan

Dear Leader Creem, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Devin Callinan
First Vice President - Wealth Management UBS Financial Services, Inc.

Subject: Protect Consumer Choice and Retirement Savings!
From: Adam Rogers

Dear Sen. Spilka, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Adam Rogers
Senior Vice President UBS

Subject: Protect Consumer Choice and Retirement Savings!
From: Glen Darby

Dear Sen. Crighton, I am a constituent and a licensed financial professional in Massachusetts and work hard on behalf of my clients every day to help them successfully prepare for major life events such as buying a home, starting a family, sending kids to college, and funding retirement. As such, I am concerned that Secretary Galvin's recent proposal to create a state specific fiduciary standard for financial representatives will limit clients' access to professional financial guidance, products, and services, while unnecessarily raising costs for my clients. We all agree that Americans should be doing more to save for retirement, and we should consider additional options to encourage savings. However, I have serious concerns about the impact the proposal will have on savers. The proposal will, among other things, require financial professionals to provide ongoing monitoring services for brokerage accounts and satisfy an unworkable conflicts elimination and avoidance standard for current and prospective clients. This business model is economically unsustainable and will result in the everyday investor losing access to cost-effective brokerage accounts. Over time, the rule proposal will likely result in a shift from brokerage accounts into fee-based advisory accounts whose higher cost structure reflects ongoing monitoring expenses. This shift will not only impact small businesses and their business models, but savers. This limitation on investor choice will force middle income savers to decide between either moving to accounts that may not suit their needs or preferences or going at it alone without personal assistance from a licensed financial professional. As a result, savers will not be able to choose what works best for them. I put the best interests of my clients first every day. I strongly support the recently established Regulation Best Interest standard put into place by the Securities and Exchange Commission, which creates a uniform best interests standard across the entire retail marketplace and preserves my clients' access to the current products and services. I urge you to ask Secretary Galvin to reconsider his rule proposal and its unintended consequences for Massachusetts investors and consumers, or at least not move forward with a new state standard until after the full impact of an implemented and enforced Reg BI can be assessed. It is imperative consumer choice is protected and that no investor loses access to advice critical to their financial stability, future goals or life planning. Thank you for your consideration.

Glen Darby
SVP UBS

Subject: Comments on Proposed Fiduciary Conduct Standard for Broker-Dealers, Agents, Investment Advisers, and Investment Adviser Representatives (950 CMR 12.200)
From: Jeffrey West

Dear Secretary Galvin:

Secretary Galvin:

I write to you today as an employee of a financial services firm who believes in the importance of putting investors' interests ahead of mine or my company's interests. As such, I fully support the establishment of an enhanced standard of conduct for financial professionals. Rather than adding to the regulatory regime, I believe this can be achieved through implementation of the Securities and Exchange Commission's (SEC) Regulation Best Interest "Reg BI" and the National Association of Insurance Commissioners' (NAIC) model regulation governing annuity sales practices.

Finalized and adopted in June 2019, the SEC's Regulation Best Interest would substantially improve protections for investors while protecting investors' choices through access to products and services. Likewise, the NAIC's model regulation, slated for completion in early 2020, would provide similar enhancements to investor protections. Already, financial services firms are updating their training materials to help financial professionals fully understand how to meet these new requirements by: amending their policies and procedures to align with Reg BI; putting new policies and procedures in place to more effectively protect investors by identifying and mitigating or eliminating conflicts of interest; and creating user-friendly disclosures to help my clients make informed decisions. I am confident that the changes made by the NAIC's updated model will similarly enhance protections for investors.

I urge you to delay the adoption of your proposal so you can carefully study and assess whether Reg BI and the NAIC model will effectively achieve the goals of your proposal. I also urge you to allow Reg BI and the NAIC model to be in effect for a reasonable amount of time before reaching any conclusions about their effectiveness in protecting investors.

Thank you for the opportunity to share my thoughts on this important issue.

Sincerely,

Sincerely,
Jeffrey West

Subject: Comments on Proposed Fiduciary Conduct Standard for Broker-Dealers, Agents, Investment Advisers, and Investment Adviser Representatives (950 CMR 12.200)
From: George Cruz

Dear Secretary Galvin:

Secretary Galvin:

I write to you today as an employee of a financial services firm who believes in the importance of putting investors' interests ahead of mine or my company's interests. As such, I fully support the establishment of an enhanced standard of conduct for financial professionals. Rather than adding to the regulatory regime, I believe this can be achieved through implementation of the Securities and Exchange Commission's (SEC) Regulation Best Interest "Reg BI" and the National Association of Insurance Commissioners' (NAIC) model regulation governing annuity sales practices.

Finalized and adopted in June 2019, the SEC's Regulation Best Interest would substantially improve protections for investors while protecting investors' choices through access to products and services. Likewise, the NAIC's model regulation, slated for completion in early 2020, would provide similar enhancements to investor protections. Already, financial services firms are updating their training materials to help financial professionals fully understand how to meet these new requirements by: amending their policies and procedures to align with Reg BI; putting new policies and procedures in place to more effectively protect investors by identifying and mitigating or eliminating conflicts of interest; and creating user-friendly disclosures to help my clients make informed decisions. I am confident that the changes made by the NAIC's updated model will similarly enhance protections for investors.

I urge you to delay the adoption of your proposal so you can carefully study and assess whether Reg BI and the NAIC model will effectively achieve the goals of your proposal. I also urge you to allow Reg BI and the NAIC model to be in effect for a reasonable amount of time before reaching any conclusions about their effectiveness in protecting investors.

Thank you for the opportunity to share my thoughts on this important issue.

Sincerely,

Sincerely,
George Cruz

Comments on Proposed Fiduciary Conduct Standard (PDF)

Robert Richard (PDF)

Mark Sparhawk (PDF)

Richard LeBranti (PDF)

Michael Patrakis (PDF)

Jeanette Fierstein (PDF)

William Berry (PDF)

Mark Scribner (PDF)

Rebecca Linhart (PDF)

Paul Verderese (PDF)

Ryan Marini (PDF)

George Bowen (PDF)

Carlos Oliveira (PDF)

Swan Shen (PDF)

Katie-Lee Kallin (PDF)

Cynthia Bremer (PDF)

Mark Paylor (PDF)

Lynn Kaplan (PDF)

John Merrill (PDF)

Kent-Niebuhr.pdf (PDF)

Bradford Smith (PDF)

Suzanne Conran (PDF)

Kevin Morse (PDF)

Complaint (PDF)

Raymond Hunt (PDF)

Robert Rano (PDF)

Devon Cooney (PDF)

Wendy Bellerive (PDF)

Walter Bonin (PDF)

Robert Sechrist (PDF)

Evan Welch (PDF)

Richard Singleton (PDF)

Tomas Cern (PDF)

Jane Ricardi (PDF)

Eric Paradis (PDF)

Christopher Barone (PDF)

John Cooney (PDF)

Regina Quirk (PDF)

Michael Quirk (PDF)

Dana Gilpatrick (PDF)

Rick Burcham (PDF)

Michael Najarian (PDF)

Clinton McHoul (PDF)

Selina Simpson (PDF)

Michelle Reid (PDF)

Carol Scatolini (PDF)

Raymond Lacourse (PDF)

Complaint (PDF)

Joseph Sullivan (PDF)

Jon Bicknell (PDF)

Laurie Goddard (PDF)

Donald Giguere (PDF)

Richard Bassett (PDF)

Matthew Little (PDF)

Robert Giargiari (PDF)

Douglas Mavilia (PDF)

Graham Merk (PDF)

Richard Doleva (PDF)

Steven Griffith (PDF)

William Ryan (PDF)

Anthony Forzano (PDF)

Marcia Sullivan (PDF)

Bryan McDavitt (PDF)

Thomas Dexter (PDF)

Kimberly Butterfield (PDF)

James Connors (PDF)

Richard Perry (PDF)

Chester McCord (PDF)

Complaint (PDF)

Dennis Franson (PDF)

Carol Ring (PDF)

Bill Casagrande (PDF)

Eugene Ellison (PDF)

Dana Bernard (PDF)

Paul Miller (PDF)

Steven Rudnyai (PDF)

Frank Patton (PDF)

Thomas Maikowski (PDF)

Kevin Myers (PDF)

Anthony Mazzotta (PDF)

David Smith (PDF)

Edwin Kulawiak (PDF)

George Walters (PDF)

Curt Coulombe (PDF)

Robert Sayre (PDF)

Aaron Cirksena (PDF)

Brenda Ramsey (PDF)

Nicholas Pappas (PDF)

Debra Scott (PDF)

Walker Heagney (PDF)

Anthony Kowalski (PDF)

Todd Powers (PDF)

John Carlson (PDF)

Derrick Kawamoto (PDF)

Peter Pace (PDF)

Donald Ciampi (PDF)

Susan Frenkel (PDF)

Wei Lee (PDF)

Bruce Lubatkin (PDF)

John Oberlander (PDF)

Lisa Karlin (PDF)

Randall Houghton (PDF)

Christopher Reiser (PDF)

Olivia Grabowski (PDF)

Stanley Smith(PDF)

Robert Cusick (PDF)

Trevor Wilde (PDF)

Robert Hensley (PDF)

Richard Canter (PDF)

Harvey Bowks (PDF)

David Nicholson (PDF)

Steven Martino (PDF)

Carl Ferrazza (PDF)

James Baker (PDF)

George Smith (PDF)

Kathryn Palao (PDF)

Richard Carlquist (PDF)

Gerald Webster (PDF)

Bob Milligan (PDF)

Glen Morris (PDF)

William Fox (PDF)

Daniel Abelson (PDF)

Michael Clark (PDF)

Stephen DeFilippis (PDF)

David T Wilson (PDF)

Travis Flandermeyer (PDF)

Steven Blanchard (PDF)

Robert Brock (PDF)

Gabriel Aufiero (PDF)

Steven Amico (PDF)

Steven Finocchiaro (PDF)

Chuck Weber (PDF)

Scott Wight (PDF)

Edward Fusco (PDF)

William Slattery (PDF)

Janet Connors (PDF)

Franklin Ator (PDF)

Donna Lescoe (PDF)

Wayne Locke (PDF)

Paul Contreri (PDF)

Anne Rubeo (PDF)

Stephanie Johnson (PDF)

William Fallon (PDF)

Stephen Murdock (PDF)

Thomas McKinnon (PDF)

John Lamontagne (PDF)

Megan Rodriguez (PDF)

Janenne Lackey (PDF)

Daniel Girard (PDF)

Michael Crotty (PDF)

Peter Bacchiocchi (PDF)

Elizabeth Corrigan (PDF)

Colin Krafft (PDF)

Kevin Hansley (PDF)

Edward Winters (PDF)

Snehal Patel (PDF)

Thomas Valentine (PDF)

George Goulas (PDF)

Kenneth Chase (PDF)

Gregg Parker (PDF)

Richard Howell (PDF)

Thomas Palm (PDF)

Gustin Fox-Smith (PDF)

Justin Littlefield (PDF)

Stanley Smith, Jr. (PDF)

Robert Weissbein (PDF)

Dean Cudworth (PDF)

Kurt Hoffer (PDF)

David Wong (PDF)

Richard Shaw (PDF)

Robert Kailes (PDF)

Debora Summers (PDF)

Roger Turcotte (PDF)

Greg Rickens (PDF)

Christopher Streich (PDF)

Curtis Beggs (PDF)

David Harding (PDF)

Charles Richardson (PDF)

Angela Brill (PDF)

David Dugan (PDF)

William Ward (PDF)

Anthony Bartlett (PDF)

Shawn Everett (PDF)

Kyle Miller (PDF)

Damon Accardi (PDF)

Jeffrey Whyte (PDF)

Joseph Accardi (PDF)

Timothy Redmond (PDF)

Jose Lopez (PDF)

David Waters (PDF)

Jon Weinstein (PDF)

Terry Curnes (PDF)

Ed Krakovsky (PDF)

Nicole Reif (PDF)

Linda Erickson (PDF)

Danielle Accardi (PDF)

Maryellen Rogers (PDF)

Todd Donofrio (PDF)

Jim Germer (PDF)

Kristina Oswald (PDF)

Everton Mandelli (PDF)

Paul Morgis (PDF)

Eric Wurtel (PDF)

Brad Konopaske (PDF)

Thomas Judge (PDF)

Victor Simon (PDF)

Terri-Ann Lindo (PDF)

Gerald Marriner (PDF)

Robert Bedrosian (PDF)

Rick Thiernau (PDF)

Jarrett Osborn (PDF)

Sean Barbour (PDF)

Kenneth Marx (PDF)

Joseph Shiman (PDF)

Thomas Langtry (PDF)

Sara McGrath (PDF)

John St Marie (PDF)

Jonathan Rogers (PDF)

Robert Endicott (PDF)

Susan Fisher (PDF)

Gregory McCue (PDF)

Jason Longtin (PDF)

Matthew Palmgren (PDF)

Kenneth Williams (PDF)

Reid Johnson(PDF)

Daniel Reagan (PDF)

Patrick Rossi (PDF)

Hugh Mann (PDF)

Opposition to the Current Proposal (PDF)

RE: Fiduciary Conduct Standards