August 24, 2004
You should withdraw the proposed rule. Allowing broker/dealers to charge a fee for service is at best confusing to the public, and mosl likely misleading. When a broker/dealer charges a fee the implication is that the consumer will receive advice but the B/D, not subject to the Investment Advisor Act is not held to the same standard as true investment advisors. Disclosure of this fact to the consumer would be inadequate. The consumer is bombarded with required disclosures already. There is little hope that they will pay enough attention to understand the distinction, especially when the salesperson presenting the disclosure benefits if they dont.