August 24, 2004
Re: Releases Nos. 34-42099 IA 1845 S7-25-99
Dear Mr. Katz:
I agree with the comment letter from the Financial Planning Association dated June 21, 2004 in its talking points and hereby request that this controversial above referenced proposal be withdrawn rather than amended.
This approach with the elimination of special compensation and other issues weakens consumer protection and allows brokers to misrepresent their fundamental sales role as one of fiduciary advisor receiving a fee for advice. Further it places advisors at a competitive disadvantage by allowing brokers to market similar programs under less rigorous regulatory standards for disclosure and advertising.
We look forward to a well-reasoned remedy and resolution.
Diane Sher, CPA, CFP