August 24, 2004
The Commission should withdraw the temporary regulation versus trying to amend. The regulation is flawed in that the public is not protected from potential fiduciary abuse. The regulation provides a loop hole for broker-dealers to appear to be investment advisors when in fact the fine print says they are not. There are ample current findings that prove or at a minimum give rise to reasonable doubt that the brokerage industry has not learned how to handle fiduciary related issues.