Letter to the SEC: Ten Proposed Reforms to Strengthen Investor Protection

A formal proposal submitted to the Securities and Exchange Commission by Raymond Mullaney, Founder and CEO of Equity Risk Sciences, drawing on 45 years of market experience spanning multiple market cycles. The letter presents ten concrete reforms to enhance the regulatory framework governing Registered Investment Advisors, designed to strengthen investor protection while elevating professional standards across the advisory industry.

The ten proposed reforms include: a clear investment risk classification system; personalized risk tolerance documentation with predefined loss thresholds; historical context education showing realistic market behavior; strengthened enforcement of Form ADV Item 8 methodology disclosures; enhanced suitability standards for conservative portfolios; mandatory “What Must Happen” disclosure for high-valuation recommendations; professional track record requirements; clear standards for technical analysis and momentum-based methods; enhanced disclosure for non-income-producing investments; and mandatory consideration and disclosure of investment-grade bond alternatives.

The letter is supported by eleven exhibits spanning 25 years of evidence — from SEC correspondence and academic analysis to 25-year quantitative studies demonstrating the predictive power of valuation-based risk measurement.