August 25, 2004
Dear Members of the SEC,
As a member of NAPFA and the FPA, I am urging the SEC to withdraw, not amend, the Rule proposal which exempts broker-dealers from registering as investment advisors under the Investment Advisors Act of 1940. Both FPA and NAPFA believe the rule is anti-competitive by creating two standards of conduct for persons offering financial planning services: one for registered investment advisers and one under NASD suitability rules and anti-consumer, by permitting non-disclosure of conflicts of interest by registered representatives.
Peggy S. Cabaniss, CFP
NAPFA-Registered Financial Advisor
HC Financial Advisors, Inc.
25 Avenida de Orinda
Orinda, Ca. 94563
pcabaniss@hcfinancial.com