September 9, 2004
I understand and accept my Fiduciary Responsibility as a Registered Investment Advisor. I do not believe anyone acting as an RIA should be exempted from the Registered Investment Advisors under the 1940 Act.
It appears to me the Act was put in place to protect the public and lay out the rules and regulations on how an RIA must carry out business. By allowing broker dealers not to be required to register under the Act you are discriminating against those RIAs who are not broker dealers. Following the rules and requirements of being a broker dealer is not the same as followig the rules and requirements of an RIA. If the SEC thinks they are the same then get rid of the Act and require all RIAs to become broker dealers.
Therefore I request that wirehouse firms be required to register as Registered Investment Advisers under the 1940 Act.