January 18, 2005
I urge you to completely withdraw the 17CFR Part 275 proposed rule. I do not know how the SEC can draw a line between financial planning services that are incidental to brokerage and those that are not. In addition, I think SECs approach to interpret financial planning as not incidental may be unworkable. Also, Brokers could use alternative marketing terms to evade the restrictions on the use of financial planning field. Lets have a law that provides a completely level playing field for everyone who purports to do financial planning.
James B. Kenney, CLU, ChFC