August 24, 2004
I believe the rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs should be withdrawn. The brokers are marketing their services as giving advice and encompassing broad financial issues customized to the individual client. That is absolutely an advisory relationship and should be held to the same high standards to which RIAs must adhere. Without having to register as investment advisors, their clients will be subject to continued high pressure sales tactics of inappropriate investments, namely those that are most profitable to the brokerage houses.