September 16, 2004
It is inconcievable that SEC regulations would encourage conflicts of interest activities without full disclosure, particularly when this industry has been through so much the past few years.
By establishing two different standards of conduct for persons offering financial planning services the SEC would be placing consumers at a disadvantage. The rule exempts brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services and products.
It places financial planners at a competitive disadvantage by allowing brokers to market similar programs under less rigorous regulatory standards for disclosure and advertising.
The Commission should restore functional regulation of investment advise under federal securities laws.
Thank you for your consideration.