August 23, 2004
I am writing to request that the the proposed rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs be removed. 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. As a financial planner, I feel we should all be held to the same higher standard. The rule also exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services. We should advocate for the consumer and for the highest level of disclosure for those involved with financial planning.