August 25, 2004
I urge the Commission to withdraw, not amend, the rule proposal exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs.
The rule is anti-competitive by creating two standards of conduct for persons offering financial planning services: one for registered investment advisers and one under NASD suitability rules.
The rule is anti-consumer, by permitting non-disclosure of conflicts of interest by registered representatives.
This is the wrong solution to a complex problem and will ultimately dummy down fiancial assistance to the general public.