September 22, 2004
As a Fee-Only Financial Planner and RIA, I must compete each week with representatives from the major broker-dealer firms that market themselves to consumers as comprehensive financial planners, wealth managers, investment advisers and portfolio managers. Whether they are actually performing such advisory services or not may be a mystery to many, they are clearly and overtly marketing themselves in the same fashion that we market our RIA firm to consumers and prospective clients. These services are not intended by anyone to be viewed by consumers as merely incidental. We are happy to, and feel obligated to, provide consumers with the full disclosure they require to make a complete and competent decision on whether they are receiving a satisfactory and valuable service that meets their needs and objectives. That knowledge requires full disclosure by all.
All Broker-dealer members should be required to offer the same level of disclosure as demanded of RIAs. Simple disclosure that a relationship is only a "brokerage account" relationship is confusing and not adequate to provide consumers with the information they need to make an informed decision.
I am opposed to the broker-dealer exemptions as provided under the proposed rule. In order to afford consumers the protection they deserve and which is owed to them by the SEC, please WITHDRAW THE RULE EXEMPTING BROKER-DEALERS.
Daniel B. Roe, CFP
1650 Lake Shore Drive
Columbus, OH 43204