August 23, 2004
I urge you to withdraw the proposed rule that would allow certain broker-dealers to operate as investment advisors but be exempt from the Investment Advisor Act of 1940.
Accountability of investment professionals must be uniform, regardless of the corporate form in which they work. Consumers and investors look to the SEC to offer protection and a level playing field. Your proposed rule removes that protection for a limited group of financial providers. Any such distinction will not be understood by the public and is not fair to other professionals who will continue to be be required to comply with the Investment Company Act of 1940.