PUBLIC SUBMISSION

As of: 5/6/15 8:41 AM

Received: May 02, 2015

Status: Pending_Post

Tracking No. 1jz-8imh-fb59

Comments Due: July 06, 2015

Submission Type: API

Docket: EBSA-2010-0050

Definition of the Term ‘‘Fiduciary’’; Conflict of Interest Rule—Retirement Investment Advice; 

Notice of proposed rulemaking and withdrawal of previous proposed rule.

Comment On: EBSA-2010-0050-0204

Definition of the Term Fiduciary; Conflict of Interest Rule-Retirement Investment Advice

Document: EBSA-2010-0050-DRAFT-0263

Comment on FR Doc # 2015-08831

Submitter Information

Name: Maneesh Shanbhag

Address: 

60 E 42nd St

Suite 2050

New York, NY, 10165

Email: maneesh@glinepartners.com

Phone: 6464708714

Organization: Greenline Partners, LLC

General Comment

The topic of who is deemed a fiduciary, and the standard they are upheld to, is very important to 

the long term retirement security of this country. For too long the financial services industry has 

been able to offer conflicted advice, and sell products with high hidden fees, to unsuspecting 

individuals and plan sponsors. The end result is people's retirement benefits are syphoned away 

from them, slowly but surely, until they have much less to fall back on at the end of their 

careers than they would otherwise. The last 30yrs of high stock and bond returns masked this 

problem as just about all investors earned some return on the capital they put at risk. But 

looking forward, when bond yields are at 2% and stock valuations indicating low future returns, 

it will be much clearer who is swimming naked.

While high fees of investment advice providers has been making headlines in recent years 

(appropriately so, and we support the views against high fees that have been expressed), I feel 

that what hasn't come to light as much is the conflicts of interest that the fees are a result of. I 

have had many family members tell me, when asked how much they pay their financial advisor, 

answer "I don't know", "nothing", or "I can't figure it out". I don't know of another industry 

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where it is so easy to hide the fees clients pay or the sales commissions and conflicts. When was 

the last time you bought a car but didn't know the price? 

These observations, while anecdotal, I know are prevalent across the country. This means our 

industry needs to be made to disclose our fees and conflicts of interest much more clearly than 

we currently are. If a client is sold a fund because it has the higher sales commission, this needs 

to be the first thing the client is told, and additionally just how difficult and long it will take to 

overcome the hurdle this initial fee represents.

In the world that I imagine, a fiduciary has no conflicts of interest. And that almost by 

definition means that things like sales commission and other kickbacks from investment product 

manufacturers are all but eliminated. Those who don't meet this standard need to disclose that 

they don't and be require to disclose it using plain English, that is not twisted (my late father inlaw had a broker that tried to convince me that even though he did not meet the fiduciary 

standard and had invested him in high commission, high fee, low performing products, that he 

was subject to an even higher standard ... disgusting). 

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