August 24, 2004
RE: Certain Broker-Dealers Deemed Not to be Investment Advisors as proposed on 11/4/99.
I believe that the public interest would be best served if broker-dealers who offer fee-based programs are required to comply with current registration requirements of the Advisers Act.
The public does not, and generally cannot, make a distinction between and investment advisor who is held to a fiduciary standard and a b/d practitioner who is not required to make similar levels of disclosure.
Similar standards should apply to anyone who holds themselves out to the public as a financial planner. Please do the right thing for the investing public.