*Letters

SIA Submits Comments to the SEC on Broker Dealers Providing Investment Advice in Certain Cases

Published on:
January 13, 2000

The Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on Proposed Rule 202(a)(11)-1, which would exclude a broker-dealer providing investment advice to customers in a fee-based account from the definition of investment adviser as long as the advice is provided on a non-discretionary basis, is solely incidental to brokerage services, and the broker-dealer discloses to customers that their accounts are brokerage accounts. In addition, the proposed rule would keep a broker-dealer providing incidental advice to customers from being subject to the Investment Advisers Act of 1940, solely because it also offers execution-only or web-based services at reduced commission rates. While SIA is in substantial agreement with the content ofthe proposed rule, they provide a few recommendations that they believe would improve the proposal by providing greater clarity.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.

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