February 4, 2005
Please reconsider and eliminate the investment advisor exemption for broker dealers.
As I watched TV this morning, one of the major brokerages consumer advertisement showed their Financial Adviser sitting on the beach with a couple suggesting they move things around in their portfolio to meet a financial goal sooner. I hardly think the average consumer will view the financial advisers advice as solely incidential to the brokerages transaction services.
Its very simple, one set of rules for all.If you hold your self out as a financial advisor or financial consultant that provides investment advice, then you should be subject to the Investment Advisors Act.