Subject: File No. 4-606
From: Dale A Walters, CPA, PFS, CFP
Affiliation: AICPA, NAPFA, FPA

March 27, 2013

My comments are as the issue should be. Clients expect the same level of care from a stock broker as they do from a registered investment advisor. Allowing this misinformation to continue is not in the public interest. So either there has to be significant improvement in public education on the issue or there needs to be consistency.

Looking at it from a different point of view, it seems logical to me and everyone I have ever talked to, that if financial professionals are claiming they are doing the same thing, they should be held to the same standard. The argument that brokers are already heavily regulated, while true, is irrelevant because they are not regulated on the topic at hand. Even if brokers were being regulated tenfold that of advisors, that only matters if the regulation applies to the topic.

So, it seems to me that the only rational thing to do is have everyone holding themselves out as financial advisors, planners, etc. should be held to the same standard. Trying to educate everyone would be much more expensive and in the end, not as effective at protecting the public.