August 23, 2004
Please KEEP the current investment advisor registration exemption, the so-called Merrill Lynch Exception, for Broker/Dealers and their representatives. I am a CFP, and have had my own Financial Planning Practice for 17 years. Years ago I was federally registered as an Investment Advisor.
As long as a licensed stockbroker does not take discretion on his/her accounts, I see no benefit from putting them under the same regulatory system as Fee-Only Advisors and Money Managers. My friends and fellow advisors who are against this rule are only trying to limit competition. Discretionary Advisors and Non-Discretionary advisors operate in two dissimilar worlds and should not be regulated in the same way. Discretion, by its very nature, exposes the public to substantially increased risks and should be regulated more stringently. Thank you for this opportunity to comment on the proposed rule change.