August 23, 2004
PLEASE WITHDRAW THE RULE EXEMPTING BROKER-DEALERS FROM THE INVESTMENT ADVISERS ACT OF 1940 WHEN OFFERING FEE-BASED BROKERAGE PROGRAMS.
I have been in the financial planning profession for 17 years. As a result of my experience, I believe this rule will cause great confusion to the public because it creates two different standards of conduct for offering financial planning services. It is pure foolishness to do so. It is unfair for both the public and those of us who are registered investment advisers.
It is also foolishness to, in effect, create a rule which exempts brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.
Please withdraw the rule exempting broker-dealers from the investment advisers act of 1940 when offering fee-based brokerage programs.