August 24, 2004
To exempt brokerage firms from the 1940 Act denies the consumer a fair comparison of competeing advisors. The more uniformity in disclosure the better the opportunity for the consumer and other advisors to make informed decisions.
I have personally interviwed new clients who had no idea the total cost of the advice and trading costs they were incurring from their brokerage firm. The performance reporting provided by the brokerage firms were all before fees were where deducted. Actual net returns were masked and could only estimated. Brokerage firms continue to collect their fees at the bringing of the quarter thus reducing the amount of capital the investor has at work for the next period.
Every investment advisor in truth is a fiduciary regardless of who their employer is. Every investment advisor must be held to the same standards. It is not in the public interest to do other wise.
It should be a requirement that each consumer receive at the intial interview a full disclosure of all potential costs whether they are shared fees, trading cost estimates, expected commissions or fee splits. Every investment advisor including all brokerage firm representives should provide this information. Once a consumer knows how and how much someone is paid they can better judge the motivation behind the advised they are receiving.For someone to say that B share funds are no load is just plain dishonest. How can something that costs a consumer a 12b1 fee paid to the brokerage firm of more than 1 percent per year be called no-load?
Firms including banks who offer free financial planning should disclose that their planners compensation is tied to how sucessfully they transfer the consumer to the insurance and brokerage components of those firms. Not enough commissions generated by the free planning advise leads to the dismissal of the planner.
Full , fair, and uniform reporting disclosure gives every investor an equal oportunity to judge where they will best served. There is no free lunch but once the total cost of doing business and who is getting paid are reveiled the consumer then can truly become and informed investor.