August 24, 2004
I urge you to please WITHDRAW, not amend, the rule proposal. I firmly believe that 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.
Please put yourself in a financial planner/registered investment advisors position and what we have to dislcose. Then, put yourself in the brokers position - and note what they dont have to disclose.
Which person has a greater fiduciary responsiblity? What are you doing for the consumer by not withdrawing this rule?