September 14, 2004
Re: File No. S7-25-99
I urge you to withdraw the rule that I understand you have sanctioned to allow stockbrokers to present themselves to the public as financial planners.
When I began serious investing, I did research to see what kind of professional advice was available and was drawn by the merits of a certified financial planner. By paying a fee for advice and receiving a disclosure document that includes methods of compensation and any conflicts of interest, I felt I gained legal as well as moral assurance that the certified financial planner is bound by the fiduciary standard to put my financial interests first.
I intentionally avoided putting my investments in the hands of a stockbroker, concerned that the "free" advice would be paid for by behind-the-scenes payments. As I understand it, stockbrokers do not have to disclose any financial incentive received for selling particular securities or any disciplinary issues faced with regulators, nor are they bound by the fiduciary standard to put clients' interests first.
Financial planning is not 'incidental' to my long-term financial well being. If stockbrokers want to be "marketed" as financial planners, they should have to live up to the SEC's rules and register as Investment Advisers under the Act of 1940.
Given the scandals and frauds that have cost investors so much in recent years, Iím stunned that the SEC would choose to loosen protection to investors. I am under the impression that part of the mission of the Securities and Exchange Commission is to protect the public. This rule invites conflict of interest on the part of the stockbroker and confusion on the part of the investor about financial planners.
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