August 23, 2004
Please WITHDRAW, not amend, the rule proposal. I believe 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. The rule proposal is in effect until final action is taken by the Commission.
The Consumer Federation of America and AARP also strongly object to the rule.