August 26, 2004
I believe this rule should be withdrawn NOT amended I believe the rule is harmful to consumers by creating two different standards of conduct for persons offering financial planning services: a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. The Consumer Federation of America and AARP also strongly object to this rule. As a financial planner I also feel this gives an unfair disclosure advantage to wirehouse brokers.