August 24, 2004
I am submitting some comments regarding the proposed BD rule. I would urge you to withdraw, not amend, the rule proposal. As a Registered Investment Advisor, I believe the rule is anti-competitive by creating two standards of conduct for persons offering financial planning services: one for myself and my colleagues registered investment advisers and one under NASD suitability rules. Also, it is anti-consumer, because it would permit non-disclosure of conflicts of interest by registered representatives. This give the BDs an unfair advantage by allowing them to not have to follow the same rules as we do.
Please withdraw the proposed BD rule and keep the level playing field we have now.