4 INVESTOR'S
RESOURCE

FoidayRUunen26 AOtR FOR LIFE

Office of Regulations and Interpretations
Employee Benefits Security Administration
U.S. Department of Labor

Attn: Conflict of Interest Rule, Room N-5655
200 Constitution Avenue, NW

Washington D.C. 20210

RE: Conflicts of Interest Rule, RIN 1210-AB32
Dear Department of Labor officials:

As an independent financial advisor with one of the largest independent broker dealers - and a 25 year veteran in the
industry - | really "Get" what the DOL proposal is trying to do. As a comprehensive wealth management team, our firm
is bound by the fiduciary standard and puts client's first. We are almost exclusively fee-based and we routinely talk
about this no-conflict-of-interest business model being far better than commission businesses.

Yet, we still see serious flaws in the DOL proposal.

Brokers will be hurt:

We are all regulated by the SEC and FINRA, annually have a broker-dealer audit, and routinely respond to screening

systems to examine our client actions every day. These insure I’m putting client interest first and seem to work just
fine.

e The DOL Proposal requires a signed contract with me before we can discuss someone's retirement needs.
Smart consumers won't sign it and most won't read it. And, while advisors already carry a lot of professional
liability, this contract also subjects us to personal liability if our specific recommendations - looking back - don’t
beat other recommendations. What person couldn't find one investment to beat another if they have all the

past returns? Lawyers will make a killing and financial advisors who stay in the business risk professional
suicide.

* Although our office is a very established firm, | fear that the proposal. may put many of the smaller or beginning
brokers out of business as margins will be further squeezed with implementing the law.

Investors - especially the small investor — will be hurt:

Personalization and customization go out the window with the adoption of this proposal. Since when do blanket
answers always provide the best advice?

« The DOL Proposal eliminates our ability to provide investors examples of the investments in their retirement.
plan that fit the basic asset classes they should be considering. People have to guess at what a well-
diversified asset allocation looks like.

* The DOL Proposal prohibits certain investments from even being offered in.IRA’s. Why limit tools and choice
for investors?

« The DOL Proposal will increase fees which we must pass on to.consumers which may force:me away from
serving small and mid-sized clients. Why legislate how clients will pay us and potentially force 1-size-fits-all-

pricing?
4100-C Essex Court Suite C + Madison, AL 35758 » 256-772-4646 + 256-772-9363 (fax)
Investor's Resource is an independent firm.
RAYMOND JAMES? - coven : « Securities Offered Through Raymond James-Financial Services, inc. Member FINRA/SIPC.

www.invresource.com


| am requesting that you contact Secretary Perez to urge him to work cooperatively with those in our industry - - listen to
the experts who will tell you that the guts of this proposal are really messed up.

I would also be happy to serve as a resource as you continue to monitor developments on this issue.
Feel free to reach out to me if | can be of service to you. | can be reached at the office address below, home address of
201 Glenridge Ct., Huntsville AL 35824, or email: shari.burnum@raymondjames.com.

“a —

, CFP®/CExPTM
President | Investor's Resource

Sincerely,