August 25, 2004
This rule will harm consumers by allowing the comingling of the duties of an adviser and a product sales person.
The 40s Act separated these functions for the benefit of the public. An adviser should represent the clients interests without concern for the products used.
Fee paying clients should be able to hold their advisors to a higher standard without the concern that their best interest has been subjegated to a product based incentive system.
Clearly, salespeople have product placement responsibilities which make them agents of the BD. This should not be shared with the responsibility of being an objective advocate of the client.
Please eliminate this rule.