January 17, 2005
Thank you for at least delaying your decision on the Merrill Lynch rule until you receive further comment. As a certified financial planner who started as a commission based planning in 1996 and became a fee-only planner in 2004, I take exception to the rule as currently written. I have worked for one of the large financial firms in this country and I know that there objectives are not to protect the client. Rules such as the Merrill Lynch rule even with the mild revision proposed does nothing to differentiate brokers from true financial planners and advisors. With all due respect, it really takes a person to get into the mind of the average consumer. Many consumers are NOT knowledgable about the financial industry and have no clue how much or even how they are truly charged for advice and/or financial products. They see big names like Merrill Lynch and feel they are automatically being protected. This is untrue of course and totally unfair to the public and the rest of the independent financial advisors who have to spend precious time and money with their ADV compliance and procedures.
To give firms like Merrill a virtual free pass you are encouraging the financial industry to look like the retail industry where firms like WALMART have an unfair competitive advantage and have driven the little guy out of business. I am proud of the fact that I am a fee-only financial planner who discloses how I get paid and the services that I offer without hiding behind the corporate veil.
Please reconsider and withdraw the Merrill Lynch rule on Feb 7th. Thank you for reading my comments.
Anthony Rossetti, CFPr
Proud member of the Financial Planning Association