August 24, 2004
I write in support of not exempting broker dealers and their representatives from the registration and disclosure requirements of the Investment Advisers Act of 1940 when offering fee-based financial planning/asset management services. I believe that full disclosure of material facts that could or would influence how consumers evaluate the financial planning and investment recommendations offered by BD affiliates is imperative to maintain the transparency and integrity of our financial markets. Do we not require publicly traded companies to report material facts that may bear on the trading of insiders for similar reasons? The charade of BDs representing themselves to the public as offering independent and objective advice when all sources of compensation soft dollars and hard dollars are not disclosed must end. Creating a level playing field for those who appear to even relatively sophisticated consumers to be operating under the Act will do much to restore public confidence in our financial institutions. Despite the near-term anxiety caused by this proposal to the BDs who would be required to register, I believe they would find a renewed respect on the part of their consitituencies clients and shareholders alikeand over the longer-term the results would be good for business, as well as just good business. Thank you for the opportunity to comment.