Subject: File No. S7-12-06
From: Curt Weil, CFP
Affiliation: Principal, Lasecke Weil Wealth Advisory Group, LLC

April 3, 2007

While the model form is, by and large, perfectly appropriate for large firms, and very useful to the consumer, it is seriously extravagant for the thousands of smaller investment advisory firms such as ours, and useless, to boot.
Our firm simply does not have a need for most of the language in the forms - which seem to be written from the perspective of a bank.
For instance, the forms state that we (the financial institution) regularly report credit history, credit scores, etc. to credit bureaus. We don't do that Never have. Never will.
The forms state that we have information about how "customers" (we have clients, not customers) pay their bills and use their credit cards. Not true, nor is there a way to so indicate on the proposed form.
Why is there nothing in this proposal that reflects the reality of different business models?
Why is there no ability to differentiate among the major models of client relationships - banks, brokerage firms, insurance firms and independent investment advisors.
Why must we be round pegs jammed into the square hole of the banking industry?

What follows is our Privacy Policy, which is appropriate for us and a model of simplicity, if I do say so myself (which I do, since I wrote it)

Privacy Policy

Our firm is committed to safeguarding the confidential information of our clients. We hold all personal data provided to us in the strictest confidence. Indeed, we require your specific permission before we will discuss your affairs with anyone external to the firm. The information we compile includes that provided by you on our questionnaire, collected from your previous advisors, if any, and from statements, transactions and other sources that you give us.

We use this information only to provide financial planning and investment management services to you in accordance with our agreement with you. We give prospective and former clients the same protections as existing clients with respect to the use of personal information.

We have never disclosed information to nonaffiliated third parties (such as brokerage firms, credit-card or insurance companies,) except as required by law, or in carrying out the duties for which you retained us. We do not anticipate any change to this policy, and, in the unlikely event that we were to change it, we will contact you prior to such a change and give you the option to protect your data.

As you know, we use health and financial information that you give us to assist you in meeting your personal financial goals while guarding against any perceived or real infringements of your privacy rights. Our policy with respect to personal information is as follows:

We limit access to information to only those employees who have a business or professional reason for knowing it, and only to nonaffiliated parties as permitted or required by law for example, federal regulations permit us to share a limited amount of information with brokerage firms in order to transact business on your behalf, and federal and state regulators, in the course of inspecting us may also have access to your data.
We maintain a secure physical office and our computer network is protected by a security firewall to ensure that your information is not placed at unreasonable risk.
For unaffiliated third parties that require access to your personal information (such as a brokerage firm,) we also require strict confidentiality in our agreements with them and expect them to keep this information private.
We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose.
Disclosure of private client information is an offense subjecting employees to termination.
We will maintain your files, with your data, as long as you are a client, and for as long thereafter as may be required by law and the CFP Board Code of Ethics and Professional Responsibility. After this required period of retention, all such information will be appropriately destroyed.

While none of this is new for us, federal legislation, the Graham-Leach-Bliley Act, requires that we communicate our policies in writing to you at the beginning of our engagement, and every year after. If more questions have been raised than answered, please let us know and we will do our best to satisfy your curiosity.

Respectfully,

Lasecke Weil Wealth Advisory Group, LLC
by Curt Weil, Privacy Policy

Our firm is committed to safeguarding the confidential information of our clients. We hold all personal data provided to us in the strictest confidence. Indeed, we require your specific permission before we will discuss your affairs with anyone external to the firm. The information we compile includes that provided by you on our questionnaire, collected from your previous advisors, if any, and from statements, transactions and other sources that you give us.

We use this information only to provide financial planning and investment management services to you in accordance with our agreement with you. We give prospective and former clients the same protections as existing clients with respect to the use of personal information.

We have never disclosed information to nonaffiliated third parties (such as brokerage firms, credit-card or insurance companies,) except as permitted by law, or in carrying out the duties for which you retained us. We do not anticipate any change to this policy, and, in the unlikely event that we were to change it, we will contact you prior to such a change and give you the option to protect your data.

As you know, we use health and financial information that you give us to assist you in meeting your personal financial goals while guarding against any perceived or real infringements of your privacy rights. Our policy with respect to personal information is as follows:

We limit access to information to only those employees who have a business or professional reason for knowing it, and only to nonaffiliated parties as permitted or required by law for example, federal regulations permit us to share a limited amount of information with brokerage firms in order to transact business on your behalf, and federal and state regulators, in the course of inspecting us may also have access to your data.
We maintain a secure physical office and our computer network is protected by a security firewall to ensure that your information is not placed at unreasonable risk.
For unaffiliated third parties that require access to your personal information (such as a brokerage firm,) we also require strict confidentiality in our agreements with them and expect them to keep this information private.
We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose.
Disclosure of private client information is an offense subjecting employees to termination.
We will maintain your files, with your data, as long as you are a client, and for as long thereafter as may be required by law and the CFP Board Code of Ethics and Professional Responsibility. After this required period of retention, all such information will be appropriately destroyed.

While none of this is new for us, federal legislation, the Graham-Leach-Bliley Act, requires that we communicate our policies in writing to you at the beginning of our engagement, and every year after. If more questions have been raised than answered, please let us know and we will do our best to satisfy your curiosity.

Respectfully,

Lasecke Weil Wealth Advisory Group, LLC

(Attached File #1: s71206-691.pdf)