August 30, 2004
I am the CEO of a company listed in Bloomberg Wealth Management Magazine as one of the premier wealth management companies in the US. I am also past president of the American Medical Association investment advisory arm. Based on my 20 plus years of experience including COO of a broker-dealer firm, I offer the following opinion:
This proposed rule should be withdrawn.
I believe that the rule is anti-competitive because it creates two standards of conduct for persons offering financial planning services: one for registered investment advisers and one under NASD suitability rules. I also believe that the proposed rule is anti-consumer since it allows non-disclosure of conflicts of interest by registered representatives.
I believe that it is important for the SEC to increase the level of trust by the consumer on the financial services industry given recent events. The proposed rule does not.
Thank you for allowing my comments.