August 23, 2004
Please withdraw, not amend, the proposed rule S7-25-99. I believe the rule is harmful to consumers by creating 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 worked for a bank broker/dealer and I know how misleading it is to the clients - when sales people want to push a product under the guise of Financial Planning. True planning by fee only advisors is the better way with less conflict of interest and it is highly regulated - fee-based planners and sales people need to be as highly regulated if not more so.
Velda A. Eugenias, CFP®
CERTIFIED FINANCIAL PLANNER™
Cedarholm & Eugenias, LLC
Financial Planning & Wealth Management
110 Bay Street
Gadsden, Alabama 35901