August 24, 2004
I would like to add my name to the list of people who requsts the Securities and Exchange Commission to withdraw or substantively amend the rule Release Nos. 34-42099 IA-1845 File No. S7-25-99 entitled Certain Broker-Dealers Deemed Not To Be Investment Advisers as proposed on November 4, 1999.
You have recently 6/21/2004 received a letter from Duane R. Thompson, Group Director, Advocacy of The Financial Planning Association. The points as outlined in this letter are expressed as I would have them expressed and I support them totally.
Full disclosure of conflicts of interest in the fee-based programs is the key to an effective rule. it is time for the Commission to restore functional regulation of investment advice under federal securities laws. Investors will benefit through consistent and comprehensive disclosure of conflicts and the related fiduciary protections of the Advisers Act by withdrawing the Rule.
Daniel J. Mannen, Jr. CFP, CRPC
Senior Financial Advisor
American Express Financial Advisors