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

August 17, 2010

To Whom It May Concern:

I could not be more opposed to the so-called "suitability standard" and could not be more in favor of a "fiduciary standard" for all who practice any or all elements of the comprehensive personal financial planning process.

I cannot imagine how it serves the public to hold different practictioners to different standards. The confusion that results causes people to rarely understand who they are really dealing with and which so-called professionals might have the necessary expertise to address their very real and very important personal financial concerns.

In the business of financial planning it seems as though people either deal with "doctors" or "drug-dealers". Both (in a medical sense) deal with "controlled substances" but Doctors generally deal with them after being educated, sworn to uphold by oath a certain set of ethics and ideals and theoretically only engage in prescribing a controlled substance to someone who has been properly diagnosed as an individual who may benefit from the treatment prescribed.

In stark contrast, those who function like "drug-dealers" tend to think of themselves first, peddle product with little need to properly diagnose before prescribing a remedy. There is nothing client/"patient" centered about the approach.

Delineating the characteristics of "Doctors" vs. "Drug Dealers" will generally give you measuring sticks by which to measure the substantive differences between the Fiduciary and the Suitability standards as they compete directly for the well being of the investing and planning public. Perhaps the comparison does not give full weight or credit to the many who under a suitability standard honestly endeavor to do what is right for the client but without a clearcut Fiduciary standard it is my opinion that the lines are left just blurred enough for the financial professional to feel satisfied being a very poor "financial physician" or a very good and capable- even a well-meaning "drug dealer".

Consider the analogy and then ask, "What professional would I feel comfortable having my own mother work with?"

That will yield the right answer almost every single time.

John A. Brinkerhoff, MSFS, CFP