August 23, 2004
It is apparent that those benefiting from exempting broker-dealers from the Investment Advisors Act of 1940 when offering fee-based brokerage programs are not the consumers, but only the broker-dealers themselves. Such a double standard is not in the spirit of ethical dealings with the public, neither in fiduciary matters nor in the disclosure of conflict of interest matters. I urge the Commission to withdraw, not amend, the rule proposal.