August 27, 2004
As a member of the FPA Financial Planning Association I concur with our collective stance of urging the SEC to WITHDRAW, not amend, the rule proposal. I believe 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.
I am dually registered and licensed under an RIA and a Series 24 securities representative. I have to fully disclose all of my potential conflicts of interest to current and prospective clients. I think this is correct way to conduct business, and I am fully opposed to anyone else who does not abide by the same rules. Oversight is a necessary function in our business to help protect the consuming public. It is high time we require anyone holding themselves out to be a professional advisor to adhere to higher standards.
Respectfully,
Mark F. Krivonak, CFP, ChFC, CLU