Subject: File No. 4-606
From: Jon R Cranney

August 29, 2010

I support efforts to more clearly define the roles of investment professionals. The problem is in distinguishing the roles of Brokers, Bankers, Investment Advisers and Insurance agents. Then one can get confused by the term account manager which could be any of these.

I would recommend determining hard and specific names for the various roles. I would begin by banning the use of "investment adviser". The service of creating a plan for investors in financial instruments (stocks, bonds, etc) should be Investment Planner. If the investment is something else, it should be thus titled -- ie Real Estate Investment Planner. Insurance agents who sell annuities should have to declare themselves Annuity Brokers. So on and so forth.

How dose an investor know which hat the financial professional is wearing when he or she discusses money issues with people who for the most part have little knowledge or sophistication. I think it should be incumbent on the professional to state very clearly what product and what advice they are giving. I would recommend a form with a checkoff list of the various services that a profession must hand to a customer at the beginning of a discussion or sales pitch.