In previous newsletters I have shared with you my election to the Board of Directors of REISA (the Real Estate Investment Securities Association) and my appointment to the Policy Committee of the IPA (Investment Program Association). Although their meetings and activities take me away from serving my clients and family time, I felt it was important to “step up” into an advocacy role on regulatory and policy issues that affect our clients, and the broader industry of non-traditional investments including non-traded REITs and BDCs, as well as oil and gas drilling programs.
Recently, the Securities and Exchange Commission solicited comments with regard to a rule change proposed by FINRA known as Notice to Members 14-06. AOG Wealth Management is known as a “hybrid” firm because we have dual roles. Most of our investments are provided to you under our Registered Investment Advisor banner, in which we are directly regulated by the Securities and Exchange Commission. Some of our specialty investments in real estate and oil and gas drilling programs are offered through Kalos Financial, which we utilize as our Broker Dealer as Registered Representatives and Registered Principles. In that capacity, we are members of FINRA, which is a self-regulatory agency under the SEC.
Some regulators and policy makers at FINRA don’t recognize the benefit of what we do by utilizing “non-traditional” or “alternative” investments to provide greater diversification, lower correlation to the broad stock markets and their typically higher, more tax efficient income distributions. In defense of FINRA, not every advisor does the extensive due diligence on these programs, or offers the robust education programs that we do. However, FINRA is attempting to use a broad brush approach to this issue to “protect” some of the less informed advisors and investors. I have attached a link to the SEC website where you can view my comment letter in full. I would be happy to discuss any of these issues with you directly. The main point of informing you about this activity is that I want you to be aware of these issues to the extent that you care, and more importantly, to assure you that AOG Wealth will continue to advocate in your best interest at the highest industry and regulatory levels.
By Frederick Baerenz
President & CEO