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7 August 2018 Comment Letter

CFA Institute Comment Letter on SEC Proposed Form CRS Summary and Titles Control

Amendments to Form ADV; Required Disclosures in Retail Communications and Restrictions on the Use of Certain Names or Titles

Kurt Schacht, JD, CFA, Jim Allen, CFA, and Linda Rittenhouse, JD

CFA Institute believes that Form CRS takes important steps to control broker titles, but overall will increase investor confusion because it does not clarify the distinctions between broker-dealers and investment advisers

CFA Institute believes that Form CRS takes important steps to control broker titles, but overall will increase investor confusion because it does not clarify the distinctions between broker-dealers and investment advisers

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CFA Institute