August 24, 2004
I believe the proposed rule which exempts broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs should be withdrawn. This rule creates two different standards of conduct for financial planning professionals who offer their services to the public. One for RIAs and another for NASD covered persons.
I am an RIA representative and associated with a broker-dealer as an RR. The public needs the assurance that any licensed financial professional is held to the same disclosure scrutiny as the next.