July 20, 2004
I am writing to strongly recommend that you withdraw the proposed rule that Certain Broker Dealers are Deemed not to be Investment Advisors.
There have been critical abuses in abundance in the past in the financial services profession; enough so that there are a multitude of jokes told about "stock brokers" (who, unless I am mistaken, now put "financial consultant" on their cards), and books written (Where are the Customers Yachts), and lawsuits galore.
What does a "financial consultant" at a broker dealer do? The answer is: they GIVE ADVICE.
And if representatives of broker dealers are holding themselves out to give financial advice, then to me it is fairly clear that they should indeed be held to the same standards of disclosure that the rest of us are.
Investment advice is a highly intangible product and service, and the potential for abuse to the consumer is high. Consumers often DON'T SEEK financial advice specifically because they are afraid of being "abused", or "taken". Itís true. You know that itís true.
Please do your part to continue to help consumers to understand exactly who they are working with, how they get paid, what their background is, etc, and please DON'T set up two sets of standards that will only serve to add more confusion to the consumer you are pledged to assist.
Cindy Storm Fischer, CFP
Annex Wealth Management
18650 W Corporate Dr Ste 300
Brookfield WI 53045