September 7, 2004
I am writing to urge the SEC to WITHDRAW, not amend, the rule proposal for registered representatives under the NASD. In an effort to better protect consumers this ruling will create 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.
As a Certified Financial Planner it is of utmost importance that consumers be protected from being mislead by securities salespersons and that there be an equal standard of conduct. Fair and open disclosure of all fees is also in the publics best interest and this ruling will not demand that of registered reps.
I encourage you to withdraw this ruling.
Respectfully submitted,.
David Morganstern,CFP