September 22, 2004
I agree with the FPA position as it concerns the Broker Dealer Rule. The proposed rule should be withdrawn, not modified. The investing public is unable to discern the difference between brokers providing advice in a sales environment and financial advisors operating in a fee only arrangement. Even well-intentioned brokers who attempt to provide objective advice to their clients must operate within the sales environment of their firm. I spent almost six years with a major brokerage firm. There is a tremendous contrast between the sales culture of that firm and that of my present firm,a fee-only planning firm in which it comes natural to provide objective advice given minimal conflict of interest. Please rescind this rule. Anyone who holds themselves out to be a financial planner, financial consultant, or investment advisor should be held to the same standards that apply to Registered Investment Advisers under the Investment Advisor Act of 1940. Thank you for your consideration of my comments.