January 14, 2005
Sometimes issues seem complicated and muddy. Allowing brokerage firms/representatives the ability to offer financial planning and investment advise without being subject to the IA act is not one of them.
I can understand the great pressure you must feel from huge brokerage firms, but you must not yield. People can see through this. And the consumer will not likely understand yet more disclosers. Especially when representatives will still be marketed as Financial Consultants and the like.
The Act has served us well for 65 years. Take courage, and do the right thing.
I urge you to completly withdraw your proposed rule. NOT revision, but withdrawl.