Can Your Edward Jones Financial Advisor Really Serve Your Best Interests?

Editor’s note: What follows is an examination of the broker-dealer business model, using the specific case of Edward Jones as an illustrative example. It’s longer than normal, but I hope you’ll find it well worth your time. -- B.R.

In 2004, the highly regarded investment firm Edward Jones stumbled over allegations that it didn't disclose important conflicts of interest. The question of whether its model possesses too many conflicts still bedevils the company and much of the financial advisory industry today.

Edward Jones agreed, without admitting any wrongdoing, to a $75 million regulatory settlement with the SEC for allegedly failing to disclose that it received tens of millions of dollars from preferred mutual fund partners each year on top of commissions and other fees.

Today, Edward Jones continues to receive revenue-sharing payments from its preferred mutual fund partners, but it provides a detailed disclosure of those payments on its website. The company earned $98.1 million in revenue-sharing payments from mutual funds and another $54.1 million from insurance product partners in 2011. It earned approximately $4.6 billion in overall revenue during the period.

Where the trouble starts
The company admits that those payments, which are common to the industry, represent potential conflicts:

We want you to understand that Edward Jones' receipt of revenue-sharing payments represents a potential conflict of interest in the form of additional financial incentive and financial benefit to the firm, its financial advisors and equity owners in connection with the sale of products from these partners.

In another document titled "The Fiduciary Dilemma" -- a memo produced by Edward Jones and circulated among congressional staffers in February 2010 -- the company conceded that there were potential conflicts of interest inherent in the broker-dealer model in general, but that its model served investors well as long as those conflicts were disclosed.

In a nutshell, the broker-dealer advisory model is one in which financial advisors provide advice and assistance to customers in return for commissions, fees, and other payments that result from financial transactions. Edward Jones argues that this model benefits ordinary investors by offering them counsel and guidance that is free, unless there is a transaction. As long as potential conflicts are disclosed, everyone wins, according to the company.

As a result of our research, we disagree with this view, and while we're great believers in disclosure, it's not enough of a protection for the ordinary investors who often see their investing returns diminished by high costs they don't always understand.

And any model that incentivizes the sale of expensive mutual funds to investors with relatively small portfolios is particularly flawed. Financial advisors at Edward Jones are primarily compensated on a straight commission basis. They get paid by selling customers financial products that generate commission revenue to the firm and themselves. Most financial advisors in the broker-dealer industry are paid on a roughly similar model. Unfortunately, academic research in behavioral ethics is pretty clear that "when people have a vested interest in seeing a problem in a certain manner, they are no longer capable of objectivity."

A case study of Main Street's broker
In order to better understand why the broker-dealer model as it is practiced today is generally inferior to a fiduciary model for individual investors seeking advice, we've taken a closer look at Edward Jones, a registered broker-dealer that has more than 12,500 advisors spread across 11,100 offices serving 7 million clients. This year, it ranked fifth in Fortune's "100 Best Companies to Work For," and it came in first  in the J.D. Power and Associates 2012 U.S. Full Service Investor Satisfaction Study.

We're not talking about a fly by-night operation here, but rather one of the most popular financial advisory firms in the country.

Because we've been critics of the broker-dealer model in the past, and after reading this series by Motley Fool blogger Sylvia Kronstadt, we set out to explore one central, guiding question: Is a broker-dealer like Edward Jones, regardless of its intentions, capable of putting the interests of its clients first?

Who's that person knocking on your door?
The financial advisors at Edward Jones come from diverse backgrounds and are provided with a great deal of training and development opportunities. Many of the former Edward Jones advisors we spoke with, however, told us that the role is primarily about gathering assets and generating revenue for the firm.

The team of financial advisors at Edward Jones has extremely high turnover, and many of the less-experienced advisors are probably unqualified to make investment recommendations. Ultimately, we found that the firm’s very business model -- which, again, is representative of broker-dealers at large -- is structured in favor of revenue generation, at the expense of providing the best possible investment advice. Importantly, our findings come despite the fact that the current and former Edward Jones advisors we spoke with are people of integrity.

According to Edward Jones Managing Partner Jim Weddle, who has been with Edward Jones since 1976, the company seeks out individuals with diverse backgrounds. The average new employee is in his or her mid-30s, and most have non-financial professional experience. "Everyone comes from somewhere," Weddle says. "We employ teachers, accountants, engineers."

Adam Koos, who earned an undergraduate degree in psychology, doesn't have a traditional financial background. Before joining Edward Jones in 2001, he was a would-be Olympic athlete who was sidelined by an injury, and considering trauma surgery. Attracted by the autonomy of the Edward Jones model, he filled out an application, passed a personality test and, with the help of headquarters, began the process of being a broker.

His story is not unusual. Edward Jones brokers come from a variety of backgrounds. One broker in Los Angeles was the former programming manager at a cable television channel; a South Carolina advisor was formerly a placement specialist at a technology staffing firm; and another from St. Louis was a shift supervisor at UPS.

And Edward Jones isn't shy about this. In a recruiting video, Kim Webb, a principal with Edward Jones, offers this piece of advice:

If you're new to the industry, what I think I'd want you to know is, it doesn't matter.

Unfortunately, recruiting individuals who have no experience providing investment advice does not inspire confidence for customers working with newer brokers. That's because the company's aggressive employee training program is mostly spent knocking on strangers' doors to gather new clients, and burnout is high for trainees who don't produce enough sales. Despite what the company says is an investment of nearly $60,000-$70,000 in every new broker hire, one of its executives told The Wall Street Journal in 2009 that 23% of new financial advisors hired by Edward Jones quit during the first four months on the job.  (UPDATE: Edward Jones officials claim that overall attrition is now below 10% and in line with other firms in the industry.)

Intense (sales) training
The word Brenda Lutz-Kiser uses to describe her initial training period at Edward Jones is "intense." Now a broker in Mooresville, N.C., Lutz-Kiser spent two months at home studying for her Series 7 & 66 exams. That the Series 7 is the barrier to entry at Edward Jones makes sense: It's the General Securities Representative exam, the qualification needed to buy and trade stocks. Series 66 is a requirement for all securities agents and investment advisor representatives.

Once she passed, she was flown, as all new hires are, to headquarters for a week of training called "Know Your Customer." "We spent an intense week at headquarters, then training in the field, knocking door to door and face to face, gathering information. It was about two months of that, then back into headquarters for another week."

"So many people start and can't make it," she says. "The training is intense, but it's the reputation we have; that we have the best training." In addition to initial training sessions at headquarters, advisors have quarterly meetings, mentorship programs and a 'boost coach" when they have difficulty meeting their targets.

Door to door (to door to door)
The door-to-door process is distinctive to Edward Jones, and it inspires love or hate from those in the field. When asked if newly hired agents were qualified to approach people's homes and discuss their investments, Weddle says it's not just the new people who go door to door. "Meeting people face to face, asking what they need, explaining how you can help, is something our people do throughout their careers at Edward Jones."

Weddle says that going door to door is the best way to build a career at Edward Jones, and that's a necessary part of serving customers. "I wouldn't invest with someone I hadn't met," he says. "I think that would be crazy."

Asset gatherers or money managers?
Koos, now the president of Libertas Wealth Management Group in Columbus, Ohio, went back to school for a degree in financial planning and has a Certified Financial Planner credential. And while both Weddle and Lutz-Kiser say career-long training is the norm at Edward Jones, Koos says he was discouraged from gaining additional certifications.

Koos says the exams he passed are not nearly enough to make Edward Jones brokers qualified to manage portfolios, and the focus on door-to-door introductions over gaining advanced financial acumen is counterintuitive. "These agents have Series 7, but they don't know what they're doing," he says. "They're asset gatherers, not money managers." 

For Lutz-Kiser, managing about 400 portfolios is a full load. She says advisors in other cities may have as many as 1,000. "If you have more people than you can call, you can't serve them."

Burnout/turnover
"Of the 14 people who were in my class from the very beginning, I think there are only four, including myself, that are still in the field," says Koos. "Everyone else moved into banking or some other non-advisory role." 

"It's a great career -- one where you can do wonderful things for your clients all while making a fantastic, unlimited amount of income -- but it's not easy, especially getting started."

Alan Canton was one Edward Jones customer whose broker left for another firm. Canton opted to follow his broker, and says he was surprised that no one tried to stop him. "No one at Jones ever bothered to call me to ask me to stay until a new broker came to the office," he says, "or to offer me an interview with other Jones brokers in the area. I was going to follow my broker anyway, but I was surprised that Jones never made any effort at all to retain me."

Koos says that most customers don't notice the turnover of agents. "Edward Jones does a good job of keeping it from their customers. Clients have learned unless you're working with someone who's been there at least three years, they won't be there long."

Lutz-Kiser, who has been with Edward Jones for four years, says that for some, finding a comfort level at Edward Jones seems to take a while. "There's definitely a hump. If someone makes it through the first three to five years, they're likely to stay." When asked if she would recommend potential clients avoid brokers who had been with Edward Jones less than five years, she says, "No, because that would mean they wouldn't work with me."

Dan Weedin, of Toro Consulting in Poulsbo, Wash., has been with his Edward Jones broker for at least 10 years. He takes an active role in his portfolio management and largely steers the planning, with his brokers' implementation. "I do also trust he is always acting in my best interest. I just like to be the one who makes the decision with his help and advice," he says. "This is a business relationship and it hasn't failed me."

Koos considers his time with Edward Jones well-spent. "At the end of the day, if I had to do it all over again, I'd still start at Jones," he says. "In my opinion, if you can't make it at Jones -- you can't make it as an advisor, on your own, anywhere."

The surprising way that your Edward Jones advisor gets paid
At this point, we need to take a closer look at how Edward Jones makes its money.

Financial advice, of course, is not free, and Edward Jones is not the only financial advisory company that derives a lot of its revenue from commissions. To its credit, Edward Jones does a very good job in disclosing how its financial advisors get paid. Here are just some of the components of one of its financial advisor's compensation:

New Edward Jones brokers are on salary for only a portion of their first year -- they eventually work solely on commissions. Advisor Lutz-Kiser was on full salary for the first six weeks. "At some point in that first year, it dropped to one-half salary," she says, "then one-quarter, so that by the end of the year, I was on commission only."

For instance, when a client pays a front-end load of 5% on a $10,000 investment in a mutual fund, the Edward Jones advisor would typically pocket 36% to 40% of the $500 commission, or about $200.

The typical financial advisor at Edward Jones is paid an hourly rate while studying for licenses and training. Having completed the training, a middle-of-the-pack advisor would earn roughly $60,550 during her first year and $62,500 (likely all from commissions) in year three. According to the company's own literature, a top-performing financial advisor would earn more than $100,000 in year three.

A tough job and an unavoidable conflict
This payment model -- not at all uncommon in the industry -- means that experienced financial advisors must sell financial products in order to get paid and meet their monthly quotas. And much of the selling is door-to-door, which requires a thick skin along with exceptional motivation and optimism. It's extremely difficult work, and we suspect that many of these financial advisors work hard for their clients.

Indeed, many of the customers we spoke with were complimentary of their brokers. Among their comments were common themes: brokers who had been with Edward Jones for several years seemed to do better by their clients in communication and disclosure and account management. Newer brokers, however, tended to cut corners either unknowingly or willfully, and leave customers feeling frustrated and wary.

On the whole, Edward Jones financial advisors stack up pretty well next to their peers in the broker-dealer industry, as the firm's J.D. Power ranking would seem to validate. Nonetheless, a straight commission model that requires the sale of expensive mutual funds does not serve the best interests of individual investors.

In Blind Spots, a standard text on behavioral ethics, professors Max Bazerman and Ann Tenbrunsel explain that reward systems "are usually well-intentioned, yet they tend to miss the mark because they fail to anticipate how employees will respond to them." In the case of Edward Jones, a straight commission model makes selling financial products the primary aim of the relationship between advisor and customer. Bazerman and Tenbrunsel's theory would argue that this model is driven by extrinsic motivation (selling more funds benefits the advisor and the firm), while discouraging "an intrinsic motivation to do what's right" for the client.

As Adam Koos put it, "if it weren't for those up-front commissions (paid by the preferred funds), I could've never put food on the table until I had enough clients to abandon the commissions. ... It sucks, but it's a conflict that you can't avoid. They paid us a salary of $24,000 for the first year. After that, I was on my own. With no clients to start with, commissions were my only income."

Why their interest is not your interest
Besides knocking on more doors to gather more client assets, another major way an Edward Jones advisor can generate revenue for the firm (and, thus, themselves) is to sell Class A shares of mutual funds.

This class comes with a front-end load that is deducted from the original investment. For an investment of $10,000, the sales charge can be as high as 5.75%, which means that $575 will be deducted right off the bat. For an investment of $100,000, the load might be around 3.5%, which would result in a $3,500 deduction. According to Edward Jones, a financial advisor receives a greater percentage of the sales charge obtained by the firm for A shares than for B or C shares.

Michael Connolly, a former Edward Jones financial advisor, told us that this approach didn't always serve the best interests of investors. If an investor wants a low-cost exchange-traded fund or index fund, according to Connolly, he or she "will be absolutely discouraged from doing so." Connolly also said no Edward Jones financial advisor is going to call you and pitch an index fund to you: "Surprise, surprise -- every financial advisor that gets your phone number will be calling with an A share mutual fund."

How loads hurt the small investor
Burton Malkiel, author of the investing classic A Random Walk Down Wall Street, told Bloomberg that "in no event should you ever buy a load fund. There's no point in paying for something if you can get it for free." This is a point that John Bogle, founder of Vanguard and a leading proponent of index funds, has made as well throughout his long career.

But advocates of front-end loads -- like Edwards Jones -- argue that they work well for investors with long-term time horizons. The investor pays for the advice upfront, and the load pays off after around eight years or so. With Class A shares, investors get access to actively managed funds and the fee for the recommendation comes right out of the investment itself.

Problem is, academic research shows that load funds consistently underperform no-load funds. The data also show that most folks hold an equity fund for approximately 3.3 years, which means, as Bloomberg put it, a front-end load is a bit like "paying a lifetime's rent for a place you might live for only a few years." While it's possible that Edward Jones' customers have longer than average time horizons, it's also important to note that investors with smaller amounts of money to invest often pay higher percentage loads on Class A shares -- a regressive tax of sorts on smaller portfolios.

It's instructive to take a closer look at a typical fund that might be sold to an Edward Jones customer. According to company filings, it received 19% of its 2011 revenue from just one mutual fund partner: American Funds. The biggest fund from American Funds is the Growth Fund of America, so it's very likely that Edward Jones clients have had this fund recommended to them.

The Growth Fund of America's Class A shares come with a 5.75% front-end load, along with total ongoing fund expenses of 0.71%. Below, we've put together a hypothetical illustration of how a $10,000 investment in Growth Fund of America A shares would stack up against a typical low-cost index fund from Vanguard.

Over 10 years, investors would have paid a whopping 13% of their initial $10,000 investment in fees, an incredible amount for what is arguably a commodity-like product. It's true, of course, that financial advice isn't free. Should it cost this much, however?

As you can see, it wasn't a great decade for equity investors in general, and the Growth Fund did outperform the index fund. Total fees and expenses, however, were so large, that the Growth Fund's profit was meaningfully smaller than the index fund's. For those investors who didn't hold for 10 years -- and we know that investors hold for much shorter periods on average -- the Growth Fund would have included a very poor fee structure for investors.

Regardless of its relative performance, Edward Jones advisors have a compelling incentive to sell this fund. The Growth Fund of America's Class A shares put money in their pockets, while also helping them to hit their monthly quotas. And financial advisors have the added incentive of selling products from the No. 1 provider of revenue-sharing payments to Edward Jones -- in 2011, American Funds paid $32.5 million in revenue-sharing to Edward Jones.

It’s important to note that Edward Jones is one of many broker-dealers making money from revenue-sharing, an industry term that describes money paid to broker-dealers by the fund companies in return for the sale of their funds. These payments are in addition to sales loads and other fees.

Investors get what they don't pay for
Edward Jones, which is organized as a limited partnership, is a profitable and growing business. As of February 2012, it had 37,000 full- and part-time employees, including 12,169 financial advisors. The partnership received 70% of its total revenue in 2011 from sales and services related to mutual fund and annuity products. Of its $4.6 billion in total revenues in 2011, $1.7 billion came from commissions with another $1.8 billion coming from asset-based fees. As mentioned earlier, its net income for the year was just shy of $500 million.

Clearly, this is a profitable model for the partners of Edward Jones. It's doubtful, however, that a model based on selling expensive load mutual funds to retail investors is delivering as much value to customers.

The fact that Edward Jones discloses possible conflicts of interest on its website -- and presumably its financial advisors disclose them over the kitchen tables of their customers -- doesn't change the fundamental calculus. Edward Jones is benefiting handsomely from all of the various financial transactions, and these benefits might outweigh those that are realized by its customers.

With cheap options like ETFs available, paying a lot for an actively managed mutual fund is the last thing a small investor should consider. Edward Jones and the entire broker-dealer advisory industry need to rethink how they practice their business model.

Are broker-dealers like Edward Jones required to serve your best interests?
Aside from these serious conflicts of interest, many investors would be surprised to know that most financial professionals who are paid to offer you advice aren't actually required to give their best advice.

That's because professionals offering personalized investment advice come in two basic flavors: "brokers," like Edward Jones and numerous other financial services firms, who are paid on commission to execute trades, and "investment advisors," who are paid a fee to manage your money. Different rules govern how they're allowed to treat clients. Fiduciary investment advisors have an ongoing legal obligation to act in the best interest of clients, whereas brokers are only required to deal fairly with clients.

But investors aren't generally aware of this fine legal distinction.

Adding to the confusion, many professionals are registered as both brokers and investment advisors, sometimes acting in a fiduciary capacity toward a client, othertimes not -- a practice known in the industry as "switching hats."

What's more, brokers often market themselves ambiguously as "financial advisors" or "financial consultants." According to an SEC-commissioned study, 59% of investors are under the impression that professionals with those designations are required to act in their client's best interest. (A separate survey by the Consumer Federation of America found that 76% of investors mistakenly believe that professionals who call themselves "financial advisors" are required to put their clients first.) Just as troubling, only 34% of investors knew that such professionals typically receive commissions based on the fees they generate through their recommendations.

Paula Hogan, founder of a Milwaukee-based fiduciary financial planning firm, explained the lack of clarity over titles: "If you go to an M.D., you know that's different than going to a chiropractor. And that's OK. But can you imagine not knowing?"

But all that might be changing. As part of the 2010 Dodd-Frank financial reform legislation, Congress gave the SEC the authority to hold brokers to the same fiduciary standard as investment advisors when making personalized recommendations.

Not everyone was happy with the idea. Prior to the law's passage, Edward Jones even circulated a document on Capitol Hill titled "The Fiduciary Dilemma," warning that a fiduciary duty could lead to "unintended consequences" that could "severely limit or prohibit the broker-dealer from providing the most appropriate investments or services to the client." It also insinuated that the law might be interpreted to prohibit commissions, thereby limiting their ability to provide "professional assistance" to "hundreds of thousands of smaller investors in this country."

In fact, both House and Senate versions of the bill would have required brokers to provide the most appropriate investment recommendations and specifically permitted brokers to continue using a commission-based model.

In early 2011, an SEC staff study recommended the SEC go ahead and hold brokers and investment advisors to the same "unified fiduciary" standard: "when providing personalized investment advice about securities ... act in the best interest of the customer."

It's unclear why, in nearly two years, the SEC still hasn't acted on the recommendation. Aside from opposition by the insurance industry, which might not be able to justify recommending expensive annuities as easily under a fiduciary standard, the most likely culprit is grueling financial industry opposition to the rest of Dodd-Frank. More than three years after the financial system overhaul was passed into law, only about one-third of its regulations are in place, as agencies have been bogged down by lobbyists, political pressure, and the threat of lawsuits.

But it's also possible the SEC is in no hurry to create a unified standard, preferring to issue a rule after brokers have been gradually eased closer toward a fiduciary standard. In recent years, FINRA, the self-regulatory organization for brokers, has been steadily beefing up its standards. Mercer Bullard, an associate professor at the University of Mississippi, believes that "FINRA rules and interpretation have expanded to reflect the broader context in which brokers advertise and deliver retail financial services, and they approach the fiduciary standard that traditionally has applied to advisory services."

Under FINRA's updated rules, brokers need to have a "reasonable basis" for believing that trades or investment strategies they recommend are "suitable" for their clients, based on factors such as age and financial situation. When selling products directly to clients, prices have to be "fair and reasonable" (the maximum permitted markup rates are 5% or lower). And brokers will be responsible for keeping an eye out for changing circumstances that could render their previous recommendations unsuitable.

That's a big improvement in the minimum permitted standards of conduct for brokers. But it still leaves the door open for brokers to advise their clients to buy expensive, underperforming products over superior ones in order to generate higher fees.

What needs to be done
The SEC needs to fix the loophole whereby professionals providing personalized investment advice are held to different standards.

When providing personalized investment advice to ordinary investors, brokers and investment advisors alike should be required to put their client first. (The CFA survey found that 97% of people agree.)

We recognize the importance of the brokerage service of processing trade orders. It serves a necessary function. But when an investor hires a professional to provide them with personalized investment advice, that professional's loyalty should be to their client for any recommendations they make.

Brokers who don't want to bear a fiduciary responsibility for their advice simply shouldn't offer personalized investment advice or advertise as a "planner," "advisor," or "consultant." Just stick with "broker" or "salesman." Advertisements and professional standards of care ought to reflect real-life functions, rather than fictitious legal distinctions between true investment advisors and sorta-investment advisors.

As professor Jim Fanto of Brooklyn Law School puts it, "You've got to really simplify things so that people aren't bamboozled and get a baseline protection when they're dealing with financial professionals. And a baseline protection means the professional is acting in their client's interest."

Investors shouldn't need to worry that they're getting fleeced by the very person who's being paid to advise them. While that's certainly not the way most brokers probably perceive their work, investors are at greater risk of being taken advantage of when their advisor is not required to put them first, has strong economic incentives to generate fees, and doesn't need to disclose those conflicts of interest in a particularly clear way.

Like investment advisors, brokers who provide investment advice should also be required to explain any important conflicts of interest in a clear way before opening an account with clients, and at relevant times during their relationship -- such as when they make recommendations.

One objection that's sometimes raised is that a fiduciary duty would interfere with brokers' commission-based funding model, thereby limiting the availability of advice for lower-income investors. That is, if brokers needed to recommend cheaper options to their customers, the reduced kickbacks from mutual fund companies wouldn't be generous enough to cover broker expenses.

But even if the reduced income really were to cripple brokers providing advice on a commission-basis, they could shift toward charging their clients an hourly or asset-based fee for advice. This would increase fee transparency, curtail conflicts of interest for brokers, and reduce distribution expenses for mutual funds.

A study by professors Michael Finke and Thomas Langdon, which compared states that hold brokers to a fiduciary standard with states that do not, indicated that a fiduciary standard doesn't seem to reduce the range of services provided, limit brokers' ability to provide tailored advice, or restrict access for lower-income clients.

Should brokers find that a fiduciary duty makes it untenable to recommend certain products -- say, expensive annuities or sketchy structured asset-backed securities -- they probably shouldn't have been recommending them in the first place. Investors could still find out about such securities from advertisements and professionals who accurately identify themselves as brokers or salesmen instead of advisors.

And if there's less "liquidity" for bad products because fiduciaries can't recommend them, that's OK. It's not the job of ordinary investors paying for advice to be the dupes of financial markets. Bad or clearly inferior products don't need liquidity. No one mourns the loss of medical saw manufacturing sales that must have occurred once doctors were able to begin treating infections with penicillin instead of amputation. Likewise, it should be viewed as a good thing for our financial health if better investment advice causes expensive, underperforming funds and annuities to be replaced with superior financial products.

As we've seen over the course of our investigation, a lot more is needed to ensure that investors receive the quality, loyalty, and care from their advisors that they deserve.

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  • Report this Comment On October 23, 2014, at 11:35 PM, RealTruth wrote:

    this a article is 'Spot On'! It is exactly portrays our experience with Edward Jones. The Edward Jones 'Financial Advisor' never told us what it would cost and consistently assured he was recommending a very conservative investment strategy that was very low risk and would not risk our capital. He invested in ~23 or more Mutual Funds and all of them were Class A. And a few days after the purchases were made our statement showed that our original investments dropped ~$15,000 dollars. We investigated and found that the drop was all do to fees, commissions, etc.. We asked Edward Jones to give us a written, detailed account of these costs and of very one who was paid with money from our acct., and that we did not knowing agree to spend this money. Our Edward Jones 'Financial Advisor' would not (and still has not) given us this information. This article is correct - they are not 'Financial Advisors' and are not obligated to look out for their clients' best interest. They are BROKERS looking to make as much money as they can (get away with) for themselves and Edward Jones. The 'Financial Advisor' title helps Edward Jones perpetuate the misconception, as this article says, that misleads their clients and lets them perpetrate a 'FRAUD' and thus a Legal theft.

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