An Open Letter to the U.S. Chamber of Commerce

Feb. 26, 2015

Tom Donahue, CEO

U.S. Chamber of Commerce

Mr. David Hirschmann

President, U.S. Chamber’s Center for Capital Markets Employee Benefits Competiveness

Mr. Randel Johnson

Senior Vice-President, U.S. Chamber of Commerce Labor Immigration and Benefits

Dear Mr. Donahue, Mr. Hischmann and Mr. Johnson:

I have observed the U.S. Chamber of Commerce undertake actions recently in apparent opposition to the U.S. Department of Labor’s (DOL's) (via its Employee Benefit Security Administration) (EBSA) re-proposal of its “Definition of Fiduciary” rule (a.k.a. “Conflicts of Interest” rule). The Chamber has suggested that the DOL should not redefine the fiduciary definition, and instead seek a more narrow approach.

Wall Street’s lobbyists are now in full press mode as they attempt to stop the Department of Labor from issuing a proposed rule on conflicts of interest. While the text of the proposed rule is not even yet known, Wall Street knows that their best shot at stopping the DOL's proposed rule on conflicts of interest is that the rule never even sees the light of day.

Introduction ... An Economic War is Taking Place

Fiduciary advocates tend to question the motives of those who oppose fiduciary standards. There is some reason for this ... the imposition of fiduciary duties, at its core, acts as a restraint on greed. The application of the fiduciary standard can (and nearly always does) lower fees and costs for individual investors.

As we approach 2015, I share with my "wish list' for the DOL, SEC, state securities regulators, and the various voluntary professional associations.

And I encourage YOU to undertake simple act, involving just a few minutes of your time, which may well serve to put us back on the path toward a true profession.



The Recent Rise of the U.S. Dollar

The U.S. currency gained in 2014 against all 31 of its major peers. The broad trade-weighted U.S. Dollar Index gained about 10% in just the last seven months (mid-2014 through January 2015). However, even with the recent surge, the dollar is only coming off historical lows, which occurred as the Federal Reserve kept interest rates extremely low for the past several years.

A different U.S. Dollar Index (which the Intercontinental Exchange Inc.

Regardless of what "size of government" you believe is appropriate (large government vs. small government), I think we can all agree that government needs to be as efficient as possible in utilizing our tax dollars. And, if investments can be made which do not raise our tax dollars now, and promise lower taxes for us all in the future, such investments deserve to be rapidly undertaken.

Here's how it works, in simple terms.

I shuddered. Even though I felt as if all my muscles were frozen, I could feel my body start shaking. My palms were instantly sweaty. Anxiety rose within me.

Professor Zigglehoffer (not his real name) then told me, “Please stand, Mr. Rhoades.” I dutifully obeyed, not certain if my legs would support my trembling body. The professor then asked, “Why did Mr. Jones not have a contract with Mr. Smith.” I cringed.

The CFP Board's exam and the AICPA's PFS exam are generally viewed as a test of the foundational knowledge one should possess to practice as a financial planner. Similarly, the CFA Institute's (tough) three-part exam leads to the award of the CFA, a prestigious largely investments-focused designation, but not necessarily an indication of wisdom and experience.

Nearly 2,000 years ago a young religious scholar, the son of a carpenter, chose to stand apart from the established religious leaders of the day. Building upon a heritage of moral virtues, he emphasized love for all, including thy enemies, as well as hope and compassion.

On this day, December 25, 2014, we are honored to celebrate his birth.

Torture is alleged to be undertaken by the CIA (under authorization, at least to an extent, from someone in the Bush Administration).