January 14, 2005
Dear SEC: The public has enough confusion on who is, and is not, an independent advisor. Unfortunately, most people think that their typical broker is giving them advice vs. being part of a marketing machine to peddle product. In an effort to reduce the confusion, anything less than COMPLETE withdrawal from the proposed rule will only contribute to the confusion. Work arounds, such as having a person for the public to call and ask questions is not a solution. The public needs a clear distinction on who is working exclusively on their behalf WITHOUT the inherent conflicts of interest that arise when financial products are bundled under the appearance of advice.
There has been enough credibility lost on our industry over the past 3 years - now is your chance to make significant amends. Protect the public and reduce the confusion: NO revisions to the rule...REMOVE the incidental rule, in its entirety, NOW.
Kevin F. Schulz, MBA, CFP