August 23, 2004
I am writing to ask that the Commission immediately withdraw this rule. Do not amend the rule - withdraw it. The rule is harmful to consumers as it creates two different standards of conduct for those persons offering financial planning services:
1/ A higher, fidiciary standard for registered investment advisers and
2/ A lower standard for those under NASD suitability rules.
The rule also effectively exempts brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.
The rule is harmful to consumers and should be withdrawn immediately.