CCMC appreciates the opportunity to comment on the SEC proposals regarding the standards of conduct for investment advisers and broker-dealers.  The proposals were published in three releases:  Regulation Best Interest, CRS Relationship Summary, and Proposed Commission Interpretation Regarding Standard of Conduct of Investment Advisers; Request for Comment on Enhancing Investment Adviser Regulation.

CCMC believes the Proposals are fundamentally sound. However, there are important aspects of each Proposal that we believe should be improved to ensure effective implementation and reduce potential adverse consequences for retail investors.