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

January 3, 2020 – William Truscott

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

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 Truscott
CEO
Columbia Threadneedle Investments and Ameriprise Financial