Subject: File No. 4-606
Affiliation: Financial Planning Association, Adjunct Professor- University of Utah and University of Virginia

August 17, 2010

To Whom It May Concern:

The fiduciary standard is good for business because it is great for the consumer. More acting in the best interest of clients means more of the public that is better served and therefore more thrilled clients that are introducing those they know to a fiduciary that is worthy of such trust.

In addition to a fiduciary standard of care, the industry is is need of other drastic reforms. Namely, the industry should be paired down to only two designations that have full-practice authority after a 5-year transitionary period giving anyone desiring full practice capabilities the option to obtain such designations. The two designations should be the CFP (Certified Financial Planner) or ChFC (Chartered Financial Consultant) and if I had my wish it would literaly be limited to the CFP. (Indcidentally, The CFP is the only professional designation requiring 1) initial education, a comprehensive examination and ongoing education, 2) a bachelors or 4 year degree, 3) experience requirements and 4)ongoing adherance to a professional code of conduct and a code of professional ethics.)

This single requirement would focus the attention on becoming a practitioner that is of sufficient independent education and experience reasonably be deemed well suited to serve the interests of the public as a fiduciary.

At the end of the 5-year transitionary period, if people are not "up to snuff" professionally, then they can continue to practice their pursuits but only within the scope and confines of a supervising CFP. This arrangement would be similar to a "physicians assistant" role in the medical profession. Perhaps they would even be forced to list as a title on their business card, "Not a Fiduciary, just an Apprentice" or "Have the equivalent of one year's training and a few lack luster licensing exams passed...Can I deal with your serious money?" Better yet, "Not independently educated (i.e. have never thought through this stuff on my own" but "my company (i.e. the product manufacturer) sure thinks this is cool, so I do, too, do you want one?"

This must be beginning to sound ridiculous to you...If so, I have succeeded in illustrating how ridiculous it is for the public to be dealing with "Drug Dealers" instead of "Financial Physcians" of sort. Perhaps we could get all the special interests and the "agent's unions" like NAIFA to sit back, take a deep breath and start doing what is right for the consumer...Not just what is right for the "factory workers".

It is just good policy to put the fiduciary standard and the public first and foremost. If we will do so by taking tough, correct, unpopular stances we will literally have the trust of the public and we all know what happens to businesses who gain such a treasure- don't we?

I hope you have many do not...We can only obtain this most precious gift by becoming a profession deserving of such trust. Won't you join me in this process?

John A. Brinkerhoff, MSFS, CFP