August 30, 2004
As a member of the FPA, I urge you to withdraw, not amend, the rule proposal. I believe the rule is anti-competitive by creating two standards of conduct for persons offering financial planning services: one for registered investment advisers and one under NASD suitability rules and anti-consumer, by permitting non-disclosure of conflicts of interest by registered representatives.
Both the Consumer Federation of America and AARP also strongly object to the rule. In the end, two standards will only hurt consumers.