July 30, 2004
Re: Incidental Advice
I am a registered representative at a major brokerage form. I extensively use our non-discretionary fee-based brokerage account platform. Many of my clients tell me that the price of a stock transaction is worth the price of a "cup of coffee." The discounters have forced the cost of a stock trade to nearly zero. It is no longer profitable for registered representatives to charge on a transaction basis.
The advice I give my clients is clearly not "incidental" as: I have an MBA from a top ten school. I hold the CFA (Chartered Financial Analyst) designation. I also have a CFP (Certified Financial Planner) certificate. I also have over eight years experience working with hundreds of clients.
Our fee-based platform includes a free financial plan for which we normally charge $1000. We typically update client's financial plans every few years.
My senior management states repeatedly that we are in the financial advice business. Most of my clients follow my guidance to invest in disciplined, well-diversified investment portfolios that are appropriate for their investment goals and risk tolerance. Most of the time, I choose all of the positions for them and recommend appropriate portfolio rebalancing over time. However, I always receive client authorization before executing any trades.
I agree with the FPA that there should be a level playing field with regards to the Advisors Act.