September 6, 2004
I am writing to request that the broker-dealer exempt rule be withdrawn.
The rule has not been adequately addressed by the SEC, which has failed to respond to the Financial Planning Associations concerns as to its wording and intent.
It would create confusion for consumers as they compare the services of a fee based advisor and a broker sponsoring a fee based program. The rule also exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services. Please move quickly to withdraw, not amend, this rule.