Comment from Ensemble Capital Management

Ensemble Capital ManagementOpposeBusiness
Summary: Ensemble Capital Management, an investment advisory firm, argues that the proposed rules incorrectly categorize investment advisors as "donor-advisors" because they do not hold distribution privileges and are already subject to SEC fiduciary duties. They contend that the new regulations would hinder capital growth for charitable purposes and request a transition period for the rules to take effect.
Please see attached letter for comment.

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