January 20, 2005
I believe the exemption for B/D rule should be withdrawn. I believe it is important for the investing public that if they believe they are working with an advisor and the advisor has conflicts of interest, those conflicts should be required to be disclosed. I do not think it is in anybodys interest except the large B/D and its RRs to try to blur the lines between a salesperson with huge conflicts of interest that are not disclosed and an advisor whose conflicts of interest are less but fully disclosed. Further, it is not that big of a deal to get registered as an advisor. It seems the only reason some dont want to get registered is because of the further disclosure required as an advisor and higher fiduciary standards. Finally, the disruption of the markets argument I dont think stands up as this exemption can be withdrawn in 90 or 120 days and many of these B/D reps are already registered as advisors.
Thank you.