January 14, 2005
I have concerns regarding your temporary rule allowing brokerage firms to offer fee-based financial planning and other advisory services until April 15. As a fee-based advisor, I ask that you withdraw this rule, not simply revise it. Here are my questions regarding potential actions by planners working under your proposed rule:
1. How should the SEC draw the line between financial planning services that are incidental to brokerage and those that are not? Can such a line realistically be drawn?
2. Do you think the SECs approach, to interpret financial planning as not solely incidental to brokerage services, is workable? Do you think there are other marketing terms that a broker could use to provide similar services and thereby evade restrictions on use of the term financial planning?
3. Should the SEC also or alternatively attempt to identify specific types of financial planning services that would or would not be incidental to the brokerage business?
Thank you for your consideration.
Charles D. White