"Brokers providing personalized investment advice to retail clients act as investment advisers and should be subject to Advisers Act jurisprudence, rules and guidance.... Brokers are already subject to a common-law fiduciary standard under securities laws for certain advisory activities, and as dual registrants .... Narrowing the broker-dealer exemption will avoid creation of a new layer of regulation and loopholes for the securities industry; and avoid higher compliance costs."  MORE >>