August 24, 2004
I am responding to the SEC proposal to exempt Broker/Dealers from the Investment Advisors Act of 1940 for fee based work. As a fifteen year veteran of the Investment and Planning industry, I have seen an uneven regulatory playing field from the beginning. I am affiliated with an RIA, have a securities license under a Broker/Dealer and am a CFP. I feel very stronly that all investment advisors, either with or without a securities license, should be required to follow the same regulatory rules and be monitored by the same regulatory bodies.
If the Federal Government wishes to protect the consumer and provide for order, my position makes incredible sense. At present, the consumer is unsure as to how my industry works. Most consumers assume an insurance agent, an RIA, a wire house rep and an independednt B/D rep with or without RIA are regulated by the same government entity.
The lobbying efforts and political pressure need to be put aside and the Government needs to decide who is in charge, have one set of regulations and one set of regulators.