September 6, 2004
Please do not exempt anyone purporting to give financial advice, from the rules applicable to financial advisors
If brokerage firms advertise and claim that they give financial advice, and charge for the financial advice that they give, then they are financial advisors and should be treated as such and regulated as such.
Additionally, the original basis for this proposed rule is the claim that asset-based fees are purely a change in transactional fee structure. This presupposes incorrectly that the existing practice of providing financial advice, under the umbrella of providing transactional services is appropriate and ethical. In fact, all professional financial advice, especially that in which the advisor stands to gain from giving that finacial advice, should be equally regulated.