Subject: File No. 4-645
From: Pamela J Horack
Affiliation: President, Pathfinder Planning LLC

March 14, 2012

My name is Pam Horack and my company is Pathfinder Planning LLC, a Registered Investment Advisor in South Carolina. I am pleased that the SEC is looking to expand financial literacy among our citizens and hope my comments and experiences will help further this goal.

My clients are young adults and families in the local area. Most have a household income between $50K - $120K and couples are well-educated. Many are one income families with small children where the mother is fortunate enough to stay home and manage the household, care for the children, and contribute to her community through churches, charities and schools.

As I work with my clients, I find they know the basics of finance. They understand the importance of saving for goals. They appreciate that they need help putting their finances in order. For this group, I find the area that is lacking is not knowledge, but budgeting skills and discipline as well as prioritizing goals.

States should set some type of financial planning standards for students at all grade levels, but the reality is that some parents will support those standards, and many will not. Our marketing society makes it very difficult to put that type of learning into practice. At minimum, all high school graduates need to be able to create and stick to a monthly budget. Again, the problem is not education, but skill proficiency.

Prior to my starting Pathfinder Planning LLC, my own financial advisor reallocated my retirement portfolio of approximately $75K into entirely new funds. I received paperwork, disclosures and prospectuses that measured 2 inches thick with messages to carefully read this information. What would have been more effective would have been a two-page letter stating the rationale for the overhaul, a list of the new investments along with associated fees, and a phone call from my representative prior to the change.

Individual investors need simplicity in regard to mutual fund disclosure and information. They are busy and do not have the time or inclination to wade through the legalese and drivel of a prospectus. These documents are best left to professional advisors and analysts. As such, professional advisors should be able to boil down the important facts for an individual to know into an easy to read one- or two-page document.

This information should include the investment name, type (open-end, closed-end, ETF) and all brokerage and advisor fees/commissions, any ongoing fee, exit fees, and other charges listed in dollar amounts. The format need to be simple and in plain English. I am pleased to see 401(k) expense disclosures at the participant level. It would be helpful to have a similar type of disclosure for other mutual fund / ETF transactions.

As far as transparency, investors expect their representative to be up front, so advisors selling products should attempt to remove any conflicts of interest. The fact that so many advisors also sell products creates an inherent conflict, so maybe selling advisors should be more forward in disclosing their payment structure.

Thank you for the opportunity for comment.

Pamela J. Horack