February 5, 2005
The new proposed rule is a step in the correct direction, but it does not go far enough. Brokers who charge a fee for investment advice should be required to register as Invesment Advisors, whether that advice is in a discretionary or a non-discretionary relationship.
Advice for a fee is investment advice, period. It is not incidental to brokerage services.
The brokerage industry has mounted a massive campaign to convice the investing public that they offer unbiased advice for a fee. They have stopped referring to their brokers as Brokers. They are Financial Consultants, Financial Advisors, or one of many other terms designed to position them as unbiased experts, rather than as the transaction salespeople brokers that they really are.
Please do not bow the powerful brokerage community in their attempts to avoid fair regulation. Small, independent, unbiased, no-commission advisors are regulated by your staff of experienced and competent inspectors. Why should the large, biased, product-driven industry giants be exempted fromn the same oversight? They should not
Thank you for your time and efforts to bring fairness and honesty to the investing public.
Roy L. Komack, B.S./M.S. in E.E., MBA, CFP