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Galvin Seeks Feedback on Fee Table for Advisors in Massachusetts

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The Massachusetts Securities Division said Thursday that it is seeking comment on rule amendments requiring investment advisors in the state to create a standalone fee table for new and existing advisory clients.

“It is not uncommon for consumers to pay different types of fees for advisory services, including retainer fees, subscription fees, and third-party robo-advisor fees,” said Secretary of State William Galvin, the state’s top securities regulator, on Thursday.

The fee table is “intended to make fees and costs more understandable and to enable investors and savers to make informed comparisons between investment advisors,” Galvin said.

Fintech innovations, for instance, have resulted in “evolving fee structures,” Galvin said. “It is no longer the case that advisors simply charge their clients a fee for assets under management.”

Galvin is seeking written comments by May 3. The Securities Division plans to hold a public hearing to receive testimony on the proposed amendments on May 2.

Galvin solicited “preliminary” comments on the idea of a fee table last February.

The request made Thursday, according to a spokesperson in Galvin’s office, “is the formal solicitation under the Massachusetts Administrative Procedures Act, which must precede promulgation of the new regulations.”

Investment advisors currently disclose information about the services that they offer and the associated fees and costs in a narrative format in Form ADV Part 2A.

The proposed amendments would require advisors to distill the information into a one-page fee table in a standalone document.

Advisors would be required to update the fee table annually and would deliver the fee table to clients prior to or at the time of signing the advisory contract.

Comments are already coming in. Daniel J. Traub, president of Tempo Financial Advisors, questions whether a standalone fee disclosure statement is “just plain overkill.”

Said Traub in a comment: “I disclose my fees in my ADV II; I disclose my fees in my marketing brochure, and my fees are disclosed in my agreement with clients (that the client has to sign). So I already disclose my fees three times. Do I really need a fourth?”

— Check out Fidelity Faces State Inquiry Over Fees Charged for 401(k) Plans on ThinkAdvisor.