Subject: File No. 4-606
From: Michael D Freker, CFP
Affiliation: member of FPA

July 28, 2010

I agree to this premise as a practicing CFP..anyone "holding themselves out as a financial planner",or related title incl designations as a CLU,CHFC,CFS,MSFS and many more are promoting a professional title and often a designation that gives the consumer a sense of trust and expertise and thus should have the "customers best interests above their own". There are however gray areas of this enforced regulation. One is that we are assuming that the customer is relaying all relevant facts concerning their financial situation. If only partial disclosure from the consumer to the advisor is given then I am not sure that the higher standard of care applies where it would influence the advice given by the professional. This can be very easy to imagine if a consumer only desires to address a "single need" such as Life Ins. or Health Insurance etc but does not fully reveal their financial position. Perhaps they are not as liquid as disclosed or have hidden debt etc.
I want the SEC to take this study seriously but with caution. Thank You..