September 12, 2004
I urge the SEC to WITHDRAW, not amend, the SEC Broker-Dealer Rule Exemption. 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. I have been both a Financial Advisor with a brokerage firm, and now currently a fee-only financial planner and investment advisor. I have no doubt that I am presently able to offer far better, consumer oriented services than in my previous capacity.