August 25, 2004
I am submitting my request for the SEC to withdraw proposed rule S7-25-99 Release Nos 34-42099 IA-1845. By having different standards of disclosure for Broker-Dealers, investors will suffer. By eliminating the special compensation factor in determining whether a broker-dealer needs to be registered as an investment adviser, investors will be stripped of the protections that investors perceive they have with the Investment Advisers Act of 1940. It is not enough to just tell investors that their investment vehicle is a brokerage account and thereby eliminating the need to inform them of any conflicts of interests that there may be in the relationship. Clients will only benefit from the full protection of the Investment Advisers Act of 1940, meaning FULL DISCLOSURE of all fiduciary conflicts, including fee arrangements. Therefore, I recommend withdrawing this rule proposal and mandating ALL investment advisors provide fair practices and full disclosure.