August 26, 2004
As an RIA Associate of my firm, I request a withdrawal of the proposed rule entitled Certain Broker-Dealers Deemed Not To Be Investment Advisors as proposed 11/4/99. Release Nos. 34-42099IA-1845 File No. S7-25-99. It is not fair to those of us who have received the specified training and registered for regulatory supervision of our fiduciary responsibilities to have to compete with brokers who have not received the specified training, registered nor fully disclosed to their clients their fiduciary responsibilities providing investment advice to customers.
This inconsistent application of disclosure standards to brokerage transactions confuses the public as well. We are trying to build trust here in a difficult investment climate.
Please help us and guide us to do the right thing by registering as RIA if we are giving investment advice, regardless of how we are compensated. Please ignore the protests of the large brokerage houses who are howling as they lose market share to independent financial planners.