September 8, 2004
I am a representative and branch manager of a NASD member broker/dealer. I believe that the SEC should rescind the so-called Merrill Lynch Rule exempting broker-dealer firms from the Investment Advisers Act of 1940. If the wirehouse brokers wish to portray their representatives as the counselors and advisors portrayed in their advertising, it seems clear that they should be held to the fiduciary standards of other regulated advisors.