August 24, 2004
I request that you withdraw rather than amend the SEC Broker-Dealer Rule Exemption.
I believe the proposed 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 offering of financial planning services. This exemption runs right into the face of increased disclosure rules and guidelines that have been put into force across this industry during the past decade. It would be like taking a giant step backwards.