August 23, 2004
I suggest dropping the proposal to exempt certain broker dealers from RIA registration.
I have nearly 20 years in the financial services industry, including holding Series 7 and 24 and 65 securities registrations as well as running my own state level registered investment advisory. In addition I have extensive fiduciary experience as court appointed conservator or protected persons, court appointed personal representative on estates, and trustee on several trusts. Finally, I am also serving as an expert witness on a trust administration matter.
With that perspective I strongly recommend that securities registered representives and their supervisors who wish offer investment advisory services be required to operate through the existing RIA regulatory structure. The bar to entry is not very high and the public should be given the extra benefit of such protection.