August 23, 2004
I urge the commission to WITHDRAW, not amend, the rule proposal. 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.
In this and future rule making, I urge the commission to encourage transparency in all financial services. As things currently stand, consumers are flummoxed by the tortured semantics used in marketing and execution of financial services. This rule would sanction more of that nonsense.
Thank you for your careful consideration in this matter.