September 15, 2004
The decision to withdraw the rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs is an easy one. It is time to do the right thing and let the investing public know you care. Having a different standard or policy for two distinct groups offering the same service does not offer the investing consumer adequate protection. It only weakens the standard of fiduciary duty owed to the customers of the investing community. I request that you withdraw the rule proposal.
Tommy G Lewis II CLU ChFC