Subject: File No. S7-25-99
From: Dan Danford, President, MBA, CRSP
Affiliation: Family Investment Center
September 8, 2004
I spent fifteen years as a bank trust officer before starting a registered investment advisory firm six years ago. I am well aware of fiduciary duties and embrace those responsibilities with my clients. My book May I Help You? Why You Need A Fee-Only Investment Advisor (Infinity 2004) explores many of these consumer topics.
I am very concerned when brokers advertise fiduciary-type services (advising, consulting) without accepting fiduciary responsibilities. It is clear from existing national advertising that these services (advising, consulting) are not incidental to their current selling practices. However, they desire to escape regulation as if they were. Among other valid reasons this is wrong (solid consumer reasons), it is also unfair to those of us legitimately registered. Industry lines should be distinct with the public - a firm either sells investment products, or they register to offer quality advice. It's possible, I guess, to do both, but it should require formal registration and related responsibilities.
Confusion over this subject is rampant, and the SEC now faces an opportunity to clarify the roles and responsibilities of industry participants. I encourage you to do so.
Dan Danford, President, MBA, CRSP
FAMILY INVESTMENT CENTER
816-233-4100 Voice / 816-233-3533 Fax
"The men who create power make an indispensable contribution to the Nationís greatness, but the men who question power make a contribution just as indispensable, especially when that questioning is disinterested, for they determine whether we use power or power uses us."
- John F. Kennedy, Amherst College, Oct 26, 1963