August 23, 2004
Re: SEC Broker-Dealer Rule Exemption
I would urge you to WITHDRAW, not amend, the rule proposal. I believe this 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. This rule also exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services. I am sorry, but I do not believe this is in the best interest of the public. Thank you for your consideration.
Frank Jacober