August 25, 2004
Dear Members of the SEC,
As a member of the FPA Financial Planning Association, I urge the SEC to withdraw, not amend, the Rule proposal #S72599 which exempts broker-dealers from registering as investment advisors under the Investment Advisors Act of 1940. I believe the rule undermines the integrity of financial advisory services by creating two standards of conduct for persons offering those services: one for registered investment advisers and one under NASD suitability rules. It is also anti-consumer, because it permits non-disclosure of conflicts of interest by registered representatives.
I believe that this rule could be harmful to citizens who rely on the financial recommendations of their advisors being unprejudiced and free of conflicts of interest.
Thank you for your serious consideration of this important consumer protection issue.