August 30, 2004
I urge the Commission to WITHDRAW, not amend, the rule proposal exempting broker-dealers from the Investment Advisers 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 advisers and a lower one under NASD suitability rules. It is my understanding that this rule also exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services. This lack of uniform standards will ultimately harm the credibility and vitality of our industry.