September 15, 2004
I strongly urge you to WITHDRAW, not amend, the rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs. I fully support the Financial Planning Association's lawsuit in federal court. The 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. Furthermore, brokers should be required to disclose conflicts of interest in connection with the offer of financial planning and investment advisory services.
Legend Financial Advisors, Inc.-«
5700 Corporate Drive, Suite 350
Pittsburgh, PA 15237
Phone: (412) 635-9210
Fax: (412) 635-9213