-----Original Message-----

From: 

Sent: Tuesday, June 16, 2015 4:11 PM

To: EBSA, E-ORI - EBSA

Subject: RIN 1210-AB32

Ladies & Gentlemen:

Obviously, from my signature block, you can see that I work in the financial industry. I have worked in 

this capacity for 15 years now; in my previous life, I was a college professor (for over 20 years) and a 

entrepreneur and investor in the world of real estate. Many of my current clients have worked with me 

for over 30 years in various business enterprises and/or they were undergraduate or graduate students 

of mine. I have maintained the highest degree of integrity and professionalism with these wonderful 

people; many of whom I consider my "extended family!" In fact, the only reason I ventured into 

financial services is because I was asked to do so by my students! I do NO marketing, but have new 

clients referred to me on a regular basis by my existing clients -- I literally love those people!

None of my clients are wealthy individuals -- they are hardworking middle (and lower-middle) class 

people. Throughout my financial career, I have ALWAYS made it my practice to place every one of my 

clients' best interests above my own financial gain -- without question -- and the income I generate from 

my practice [when compared to my book of business] is a testament to that truth. I could easily have 

tripled my income if I were to move clients to more costly investment products!

Having this information as your frame of reference, I would like to offer my opinion on the possible 

outcome of placing a fiduciary requirement on every retirement-related service we provide, and 

reducing [or eliminating] trails or residuals we receive when working with small, lower-middle and 

middle class clients. I can see where these types of changes within the financial services industry would 

be detrimental [and possibly as extreme as "catastrophic"] to the small investor. There is already (and 

has always been) a problem with mega-producers avoiding smaller investors believing that they are a 

"waste of their time." Personally, I have never valued an individual on the basis of their assets -- I value 

individuals on the quality of their very being! This is precisely the reason that I have so many small 

investors as clients -- no huge producers with mega-marketing budgets want the smaller clients. Placing 

additional statutory requirements, and reducing income potential, will ONLY serve to exacerbate this 

situation. In fact, the possibility of additional requirements, coupled with the likelihood of reduced 

income, will most certainly bring me to a decision that I am not quite ready to make [but will likely move 

in that direction] -- retiring from the industry and returning to the teaching field. Quite simply, I could 

not afford to stay in the financial services industry, serving the small client!

If the DOL necessitates a fiduciary relationship on ALL retirement clients -- while, at the same time, 

reducing or eliminating trails paid on mutual funds -- I can imagine most advisors having all of their 

clients move their retirement monies/investments into managed money platforms which, oddly enough, 

require a much higher fee structure, but do have the added "advantage" of a fiduciary relationship! If 

your goal is to have a fiduciary relationship requirement, I would strongly recommend that you make 

NO OTHER changes to the remuneration system -- that action alone will drive most of the ethical 

representatives serving the needs of the lower-middle and middle class clients right out of the business! 

Count me in on that group -- I refuse to do anything that I find to be morally egregious! I do not 

consider myself a saint, but I do believe in doing the very best for everyone with whom I do business. 
When I get up in the morning and look at myself in the mirror, I want to feel good about the person 

whose reflection I see.

Please also keep in mind that the actions you are contemplating will limit the choices available to small 

investors. As we all know, limited choices are NOT a good thing for the consumer.

I rarely will take the time necessary to write this type of heartfelt letter, but this particular situation will 

likely result in such a dangerous outcome to such a large number of people -- the lower-middle and 

middle class investor -- I felt that it would be a tremendous disservice to these people if I took no action 

and did not make my voice heard! The United States already faces a huge crisis in the future with 

millions of Americans not adequately prepared for funding their retirement years; I believe the outcome 

of the current negotiations will only multiply the number of people unprepared because those 

individuals will not be able to locate and afford to pay for competent, professional financial advice.

Please consider the possible outcome of your decisions before implementing drastic changes.

Thank you for your time and consideration.

Financial Advisor

Investment Adviser Representative

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