August 24, 2004
The last several years has shown that there is much trouble in American finance. From Enrons cooking the books to mutual funds favoritism, it is apparent that more disclosure is needed when firms deal with the public.
That is why I urge you to withdraw this proposed rule. As the saying goes, if it quacks like a duck, its a duck so aptly applies here. If a registered investment advisor gives advice for a fee and a broker gives advice for a fee...whats the difference?
Brokers are already advertising how they are hand-holding you through the financial decisions of life. That doesnt sound like they consider the advice to be a minor ancillary function to their sales profession. It they are no longer charging commissions for selling products, but rather are charging a percent of the assets they are managing, it is really hard to see how they are not doing the job that is regulated as an investment advisor, rather than a sales broker.