August 23, 2004
I urge the Commission to WITHDRAW your proposed rule exempting broker-dealers from the Investment Advisors Act of 1940 when offering fee-based brokerage programs.
I believe this rule is harmful to consumers by creating two different standards of conduct for persons offering financial planning services: a higher fiduciary standard for registered investment advisors and a lower one under NASD suitability rules.
The proposed rule is also harmful because it exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.
Thank you for your attention to this request.
Jeff W. Hinger