I am strongly opposed to this proposed change that only serves to further confuse the consumer seeking investment counsel. As stated in the proposal:
"Finally, the proposed rule would require that all advertisements for the accounts and all agreements and contracts governing the operation of the accounts contain a prominent statement that the accounts are brokerage accounts.18 We have observed that some broker-dealers offering these new accounts have heavily marketed them based on the advisory services provided rather than the execution services, which raises troubling questions as to whether the advisory services are not (or will be perceived by investors not to be) incidental to the brokerage services. We have, however, never viewed the broker-dealer exception as precluding a broker-dealer from marketing itself as providing some amount of advisory services.19 Comment is requested as to whether, instead of the proposed disclosure, we should preclude brokers from relying on the rule if they market these accounts in such a way as to suggest they are advisory accounts."
Not only have you added a layer of consumer confusion, but now you must also interpret the brokers marketing to determine if they "suggest they are advisory accounts." The broker can "change his stripes" as convenient in his or her own interest and be an advisor to some clients, a salesman to others.
Please move back to a position of regulation to protect the consumer and away from a position that appears to cater to the best interests of broker-dealers and their pocketbooks.
Charles L. Parker, Jr., CFP
Parker Financial Advisors