September 17, 2004
I am writing to ask you to withdraw the broker dealer exemption, as it causes confusion. The Registered Investment Adviser is subject to certain standards such as fiduciary responsibility to act in the clients interest, full disclosure of fees and disclosure of any conflicts of interest, and the requirement to deliver ADV documentation.
The broker dealer only has the requirement of the NASD know your client rules which are not at the same level of standard.
People in organizations performing the same work should be regulated in the same way so the public is not confused and is receiving the same product. The broker dealers need to be held to the same standard.
Please withdraw the broker dealer exemption. Broker dealers should comply with the same RIA regulations.