August 25, 2004
I understand that you are reopening for public comment a controversial rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs.
I urge you to WITHDRAW, not amend, the rule proposal. I believe the rule is harmful to consumers by creating two different standards of conduct for persons offering financial planning services: a higher fiduciary standard for registered investment advisers and a lower one under NASD suitability rules.
I understand that the Consumer Federation of America and the AARP also strongly object to the rule. That should tell you something
Please do the right thing.