September 14, 2004
This is the first time that I have ever sent a comment to the SEC. I am doing so since I believe that the rule proposal exempting broker-dealers from the Investment Advisers Act of 1940 is not in the best interest of consumers. I urge the SEC to WITHDRAW the rule proposal.
If enacted the rule would be very harmful to consumers. It would create two different standards of conduct for persons offering financial planning services. One would be a higher fiduciary standard for registered investment advisers. The other would be a lower one under NASD suitability rules. The rule in effect exempts brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.
The rule proposal is not in the best interests of the consuming public. Please WITHDRAW the rule.
Thank you for listening. You efforts and concerns on behalf of consumers are appreciated.