September 14, 2004
RE: File # S7-25-99.
As an investor, I find it perplexing -- and alarming -- that the SEC has sanctioned a rule allowing stockbrokers to present themselves to the public as financial planners.
This rule is plainly deceptive. Would you permit a paralegal to hold him- or herself out to the public as an attorney and able to give legal advice? Would the U.S. Government allow a nurse practitioner to advertise him/herself as a fully qualified physician? Of course not. Yet that is exactly what the SEC is doing by allowing stockbrokers to set themselves up as financial planners.
I regard this rule as a serious breach of the SEC's own fiduciary responsibility to the American public. You are supposed to be protecting the interests of the investing public, not permitting a sham to be perpetrated on the American investor. After the various frauds perpetrated on the investing public in recent years, it is unconscionable that such a travesty should be allowed to persist.
I am writing to state unequivocally that the SEC should withdraw the rule. Financial planning is not 'incidental' to my long-term financial well-being, and you should be not be regarding it as such. Over the years, I have had many experiences with stock brokers and with certified financial planners. There are huge differences between them; your failure to acknowledge these differences is naive, at best, and unconscionable at worst.
If stockbrokers want to hold themselves out as financial planners, they should have to live up to the SEC's own rules and register as Investment Advisers under the Act of 1940.
For the SEC not to require this is, in my mind, a clear indication of lack of your objectivity and a clear failure of your obligation to the protect the public. Please recall why your Commission exists in the first place.
Thank you for your consideration.
1205 No. Powhatan Street
Arlington, VA 22205