August 23, 2004
I urge the SEC to WITHDRAW, not amend, the proposed rule. I believe that the 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. The rule also exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.
The Consumer Federation of America and AARP also strongly object to the proposed rule.