August 23, 2004
Please withdraw your proposed rule exempting Broker Dealers from the Investment Advisers Act of 1940 when they offer fee-based brokerage programs.
We dont need two different standards of conduct for persons offering financial planning services. One higher standard for registered investment advisors and a lower standard under NASD suitability rules for Broker Dealers. The rule also exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.
The Consumer Federation of America and the AARP organization also strongly object to the rule.
Michael A. Hull, CFP, RFC, CPhD