August 23, 2004
I believe the proposed SEC Broker-Dealer Rule Exemption is harmful to consumers because it creates 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. I believe the Commission should WITHDRAW, not amend the rule proposal.