August 24, 2004
I strongly urge the Securities Exchange Commission to WITHDRAW, not amend, the rule proposal exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs . I believe that this rule is harmful to consumers by creating two different standards of conduct for persons offering financial planning services: a higher fiduciary standard for registered investment advisers and a lower one under NASD suitability rules. The rule also exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services. How can it protect the public by exempting those advisors who have most often abused their position by providing advice which is biased and often proposes investments which are the most advantageous to the broker. Please WITHDRAW this proposal