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Massachusetts Floats Fee Table Requirement for Advisors

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The Massachusetts Securities Division wants advisors registered in the state to provide feedback on a proposed rule requiring them to create a fee table for their clients.

“It is not uncommon today for consumers to pay different types of fees for advisory services, including retainer fees, subscription fees, or third-party robo-advisor fees,” said Commonwealth Secretary William Galvin, the state’s top securities regulator, in a Wednesday statement.

The proposed fee table is designed to increase transparency, aid comprehension of advisory fees, and enable investors to comparison-shop for an advisor.

“It is no longer the case that advisors only charge their clients a fee for assets under management,” Galvin said. “Recent changes that have occurred in the financial services industry, many fueled by fintech innovations, have resulted in an evolving fee structure for investment advisors.”

Advisors would be required to deliver the fee table to current and prospective advisory clients and include it on their websites.

Galvin says he is seeking suggestions on other methods in lieu of a fee table.

Other questions he is asking include:

  • If an investment advisor’s fee includes the fees of subadvisors within it, how should investment advisors disclose the advisory fees of these third-party money managers and robo-advisors to clients?
  • How should additional fees charged by parties other than the investment advisor, such as mutual fund fees or trading costs, be disclosed? The proposed fee table does not include third-party commissions or costs. Should commissions, markups or brokerage fees of the client’s custodian be included in the proposed fee table? If not, why?
  • The proposed fee table includes a field for total fees. Are advisors able to readily disclose the total fees for their services? Would the total fee disclosure be understandable to consumers?

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