August 26, 2004
This concerns the proposed rule change to exempt broker/dealers from the Investment Advisors Act of 1940 when offering fee-based brokerage programs. One of the reasons is that there are already rules in place for this type of program and there shouldnt be any use in duplicating them. Another reason is that some brokers feel they are under different standards and dont need to adequately disclose information to their clients. Allowing this exemption would put them under less stringent rules which could adversely affect clients who may not fully understand the program they are in.
I urge you to withdraw this proposal.