January 14, 2005
I urge the SEC to completely withdraw the exception for brokerage firms that currently allows them to offer advisory services.
As an independent advisor formerly at a Wall Street firm, I feel that there needs to be a clear distinction between brokerage and advisory services. That the big firms call their brokers financial advisors and financial consultants is one indication that the difference is confusing to the public. Another is that these same firms are aggressively pushing their brokers to increase the percentage of revenue coming from fee-based programs.
I would ask the SEC to look at this last point--the significant upswing in fee-based accounts at the wirehouses--as evidence that these firms are taking advantage of the incidental rule. It would be a simple task to track this trend and to gather evidence from company training materials, etc.