August 24, 2004
As an independent investment advisor in NY, I stronly urge you to withdraw, not amend, the rule exempting broker/dealers from the Investment Advisors Act of 1940. I believe that the rule is anti-competitive by creating two standards of conduct for persons offering financial planning services: one for registered investment advisers and one under NASD suitability rules and anti-consumer, by permitting non-disclosure of conflicts of interest by registered representatives. I join other organizations including the Consumer Federation of America and AARP in strongly objecting to the rule.
Steven P. Copeland, CFP