August 24, 2004
As a practicing independent financial planner, I urge the Commission to reconsider implementation of the so-called broker-dealer exemption from the investment advisor act. All of the major wirehouses are marketing their services to the public under the rubric of providing financial plans to their customers, not just to facilitate securities transactions. It is unfair to hold non-broker financial planners to a higher fiduciary standard when brokerage firms claim to offer the same services we do. That hardly qualifies as incidental advice, in my mind. The public needs equal protection from abuse at the hands of an unscrupulous advisor, no matter where he/she works.