January 15, 2005
I am in complete disagreement with the proposed new rule. While I agree with the potential need for additional disclosure for clear delineation of a brokerage account which is commission based vs. fee based account. I think the new rule has gone too far. Current SEC requirements concerning registration and issuance of ADV part II is adequate in my opinion.
Also under current NASD regulations requiring know your customer rule, you have to do some financial planning to understand your clients goals and current financial capabilities. So financial planning cannot be purely incendential to a brokerage account.
Stephen C. Houser CPA CFP