September 1, 2004
I am writing to urge withdrawal of the rule proposal exempting broker-dealers from the Act. As a CPA providing investment advisory advosory services I am currently subject to regulation by the Commonwealth of Massachusetts, and if my asset base were in excess of 25,000,000 would be subject to SEC regulation. It makes no sense to me that broker-dealers get a blanket exemption for an identiacl service provided. If you plan on issuing such blanket exemptions, at least be fair and issue a clear blanket exemttion for CPAs providing investment advisory services to their clients.
The proposed blanket exemption further makes no sense considering the class of exempt persons or institutions. There is no group which has been in the public spotlight on more occasions for actions detrimental to the average investor than the group whom you are proposing to exempt from a fiduciary standard in dealing with the public. They are in desperate need of additional regulation/education as to what it means to place the clients needs ahead of your own pocketbook