September 22, 2004
I am an investor, and I believe the Rule is detrimental to consumer protection by allowing broker-dealers to avoid the
fiduciary protections of the Investment Advisers Act of 1940.
By eliminating special compensation as a critical element in the contractual relationship, the Rule permits stockbrokers to misrepresent their fundamental sales role as one of a fiduciary adviser receiving a fee for advice.
The rule also exempts brokers, in effect, from being required to disclose conflicts of interest in connection with the offer of financial planning services and products.
Adoption of the Rule would be contrary to my best interest, and the best interest of investors in general.
I respectfully request that the Rule be withdrawn.