From: Glen Clemans [mailto:gclemans@royalaa.com] 

Sent: Tuesday, March 15, 2011 8:34 PM 

To: EBSA, E-ORI - EBSA 

Cc: Jamieson Grabenhorst; Casey Cleveland; h.clemans@verizon.net 

Subject: Public Hearing on Definition of Fiduciary

This is to express my grave concern over the potential unintended consequences of the proposed 

changes to Individual Retirement Accounts.

 

As I understand it, under the new ruling, commissions and 12b1 training compensation could not 

be paid in IRA accounts. My concern is this ruling would block access to quality advice for 

millions of small investors.

 

I have been in this industry for 24 years. Our firm has thousands of clients. We specialize in 

providing high quality advice to small and mid sized investors who might be overlooked by larger 

firms.

 

The up front commission on a Class A share adequately compensates us for the time in 

developing a plan and allocation for clients.

 

Implementation is just the beginning. We perform regular portfolio reviews meetings, 

suggest NAV exchanges when appropriate, research all manner of things for our clients and are 

there for them when they need us.

 

To do this, we have a large staff dedicated solely to client services. The 12b1 trailing 

compensation is what pays their salaries so that I can provide these services.

 

Small and mid sized clients might not qualify for a fee based account, or if they do, the total cost 

to the client would be much higher than the present 12b1 fee, which is generally only 25bp.

 

Over the past 24 years I have developed important relationships with hundreds of clients. I 

sincerely hope to be able to be there for them in the next 24 years and beyond. Under the 

current proposal, this will not be feasible.

 

Thank you for your attention to this

 

Glen Clemans 

Senior Partner

CGC Financial Services

Five Centerpointe Drive, Suite 270

Lake Oswego, OR 97035

T: 503-670-1958

F: 503-670-1964

gclemans@royalaa.com

 

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Advisory services offered through CGC Financial Services, A Registered Investment Advisor, not 

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