September 11, 2004
I urge the Commission to withdraw the proposed rule exempting broker-dealers from the Investment Advisers Act of 1940. There is an increasing trend for broker-dealers to hold themselves out as providing investment advice as part of their services.
I believe the proposed rule is confusing and misleading to to consumers by creating two different standards of conduct for persons offering financial planning services. Based on the advertising I see, I dont see how broker-dealers qualify for the exemption.
The Commission should act to level the playing field for all firms offering investment advisory services by withdrawing this proposed rule and its resulting exemption for broker-dealers from the investment advisory rules.