While we wholeheartedly embrace the Commission's stated goal of providing more choices to consumers, we believe the proposal falls far short of accomplishing that goal. In our view, consumer choice may be further restricted, rather than enhanced, as a result of new regulatory demands imposed upon both existing service providers and future MDPs that are not controlled by lawyers. In theory, this should open the door to more cost-efficient and convenient services for consumers. The cost and inconvenience of complying with the Commission's regulatory scheme will discourage organizations from offering the type of coordinated services we envisioned. While we support the concept of providing reasonable protections for consumers in areas such as conflicts of interest, we do not believe it is appropriate to impose unnecessarily burdensome regulations, especially when they are applied to one type of organization but not to all.
Lawyers work in a variety of settings, providing a vast array of services to consumers.
Many lawyers work in tax preparation firms, offering tax advice to consumers based on their understanding of and experience with our tax system. Stock brokerages employ lawyers to provide investment advice to consumers. Architectural and engineering offices often employ a lawyer with experience in zoning and environmental issues to help them design an addition to a house. An adoption agency may employ a lawyer to help advise clients on procedural issues. We do not believe that there is any basis for the bar to unilaterally impose its rules on these individuals or the organizations within which they work.