September 17, 2004
I suggest that you withdraw the rule exempting the broker dealers from the 1940 Investment Advisor Act when offering so called fee based brokerage programs. It is harmful to the public as it confuses the terminology of what is fee based and its operations.
Also, standards of conduct should be flat accross the board when offering advice. A double standard serves no one, and when there are conflicts of interest disclosure is the best policy.