August 26, 2004
I urge you to WITHDRAW, not amend, the proposed rule for two reasons:
1. The proposed rule allows 2 standards of conduct. One for Registered Investment Advisors and a different, less stringent one, for Stockbrokers and their firms.
2. The proposed rule is anti-consumer. By permitting non-disclosure of conflicts of interest, it allows stockbrokers and their firms to misrepresent their primary sales role as one of a fiduciary advisor by receiving a fee for advise.