January 16, 2005
I believe that this act should be withdrawn completely.
It appears that Broker-dealers would have the opportunity to provide advisory services similar to, or the same as, those that investment advisers provide. If this is so, then all providers of investment advice should be subject to the Advisers Act. I believe that the adoption of the rule would be an act of willful negligence on the part of the SEC allowing potentially devastating abuses by unscrupulous brokerage operations on the investments and futures of their clients.
An undustry that MUST be intentionally and tightly regulated to ensure proper fiduciary planner/client relationships cannot be pushed into decline by its own regulatory agency for the sole purpose of allowing a lesser level of oversight on an issue that is so fundamentally critical as the financial future of its clients.
Consider this as though you were discussing the impact that this would have on your parents, siblings and childrens financial future. Then determine if you, personally, would want to allow a greater risk than that which is already in the marketplace.
Please withdraw this Act... for the sake of people everywhere that are just like you. Expect the highest standards when it comes to your investments and those of your constituency.
H. Vince Synan