August 23, 2004
I urge you to WITHDRAW, not amend, the rule proposal. This rule is harmful to consumers because 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. The rule also exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.
Lets keep our industry standards high.