September 16, 2004
As a practicing financial advisor, I urge you to Withdraw the proposed Merrill Rule, as technically named above. I believe, as do many in my field, that this rule creates a double standard in our industry that is detrimental to consumers who seek our advice. If advice is given pertaining to investments, or other financial planning matters, one assumes a fiduciary role. Exempting one group, while enforcing fiduciary standards on another, sends a muttled message to consumers about who they can trust, and what types of advice they will receive.
With your inability to regulate the mutual fund industry, and all of the problems we have seen on the periphery of financial planning, opening the door for Borker/Dealers now would be against everything we have learned from the mutual fund scandals.