August 23, 2004
Please withdrawl your rule. Do not ammend the rule. I and the FPA believes the rule is harmful to consumers by creating 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.