August 24, 2004
I am commenting to support the FPA, the Consumer Federation of America, and the AARP regarding the controversial rule exempting broker-dealers from the Investment Advisors Act of 1940 when offering fee-based brokerage programs. This rule creates an unfair playing field and is anti-competitive, by creating two standards of conduct for those offering financial planning services. The rule is also anti-consumer since it prevents consumers from having full disclosure and transparency. It is a bad rule and should be withdrawn completely.