August 23, 2004
I urge the SEC to withdraw, not amend, the rule proposal. The FPA believes the rule is harmful to consumers by creating two different standards of conduct for people offering financial planning services - - a higher fiduciary standard for RIAs and a lower standard for brokers, etc. under NASD suitability rules. The rule also exempts brokers from being required to disclose conflicts of interest in connection with offering financial planning services this is not in the best interest of consumers.
Finally, I would like to note that both the Consumer Federation of America and AARP strongly object to the rule for similar reasons as those I stated above.