February 7, 2005
I urge you to withdraw this rule. As an Investment Advisor Representative, I believe the rule to be harmful and confusing to consumers. It creates 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. In addition, it provides an unfair burden of compliance on typically smaller investment advisory firms while allowing larger firms to ignore important compliance procedures.