August 31, 2004
I believe that the proposed rule to exempt broker/dealers offering fee based programs from the requirements of the Securities Act of 1940 is not in the best interest of consumers and I urge you to WITHDRAW it.
Many of these firms are actively marketing themselves as trusted advisors rather than sellers of various financial services and products. If they want to market themselves as advisors, they should be willing to submit their advisory activities to appropriate regulatory oversight.
Further, the movement away from defined benefit plans and medical coverage provided by employers has shifted the onus of ensuring financial well being to the individual, who is more likely to be poorly informed about financial planning strategies. In such an environment, the need for sound, objective financial advice will increase. In my opinion, exempting broker/dealers from regulatory oversight is a disservice to an increasingly vulnerable consumer population.