September 10, 2004
To whom it may concern:
I am both an investor, and a Certified Financial Planner, so I have multiple reasons to be concerned about the outcome of the above File No.
I urge you to withdraw this rule, as it is a disservice and a danger to an unsuspecting public.
Having spoken with many consumers who have become clients of our fee-only firm, and who have come to us from the brokerage community where they "thought" they were getting financial planning advice, I can verify that allowing brokers to hold themselves out as financial consultants is extremely misleading to the consumer, especially when that broker is not subject to any enforcement action under the 1940 Investment Advisers Act.
The brokerage community has done enough damage to the reputation of the general financial services community within the context of offering financial planning advice, and there is enough evidence in the number of NASD arbitration cases brought by consumers, that the decision to withdraw this rule should be self-eveident at this point.
Please do the right thing for American consumers.
Withdraw the rule.
Best regards,
Mark Willoughby, CFP, CFA.