August 24, 2004
-I urge the Commission to reconsider to reconsider its rule exempting broker-dealers from the Investment Company Act of 1940. In light of recent events in various areas in the investment community, it is manifestly important that regulatory oversight not be weakened. Furthermore, it is a fundamental issue of fairness that all parties offering the same type of services should be regulated in the same manner. Although broker-dealers are regulated, they are not held to the same level of fiduciary care as an investment advisor.
I also call to your attention that groups as diverse as the American Association of Retired Persons and the Consumer Federation of America strongly object to the rule.
Thank you for your consideration.