August 26, 2004
I urge you to WITHDRAW the proposed rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs.
The securities brokerage industry is working as hard as it can to persuade the investing public that it moving toward a fee-compensated model for offering investment advice.
To allow this entire industry an exemption from regulation under the Investment Advisers Act of 1940 on the pretext that their investment advice is merely incidental to their brokerage service would make a mockery of your mission to protect the investing public.
Please do not modify the broker-dealer exemption rule. Completely withdraw it and resume your obligation to protect the public from the predatory practices of brokers who put their own financial interests far ahead of the interests of their customers.