August 24, 2004
I urge the commission to withdraw the rule proposal exempting Broker dealers from disclosures under the Act of 1940.
The would be anti-consumer. Coming on the heels of the obvious disregard for the consumer perpetrated by the largest of the nations broker dealers it appears completely out of step with the regulatory environment and would create an unlevel playing field as well.
I am an independent CFP licensee and have a fee based practice that is under what I feel is an outstandingly ethical Broker dealer firm. However this new rule proposal would undoubtedly create more opportunity for consumer abuse at the bd firms more likely to take advantage of the loopholes and enable unethical registered reps at otherwise compliant independent bds have cover for their shortcomings.
Thank you for your interest.