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

January 3, 2020 – Christopher Civale

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