August 23, 2004
Dear Securities and Exchange Commission:
Please withdraw the proposed rule exempting broker-dealers from the requirements of the Investment Advisors Act of 1940 when it comes to the offering of fee-based brokerage programs.
This rule in biased in favor of broker-dealers when it comes to fee-based brokerage programs at the expense of other securities licensed individuals and companies that are and will continue to be required to follow existing disclosure rules. Also, the public is not well served by such an exemption. The public should be protected by the SEC from potential conflicts of interest and if this rule is adopted in any form granting an exemption for broker-dealers when offering fee-based brokerage programs, then I believe that the SEC would not be acting in the best interest of the public.
I strongly request that the SEC totally withdraw the proposed exemption.
Sincerely,
Daniel D. Sheehan, CFP/R/
President
Sheehan Life Planning