Subject: File No. S7-12-10
From: Richard L Pugh, CFP
Affiliation: Instructor - The American College and University of North Carolina, Wilmington

May 2, 2012

I find the rules to be nonsensical and certainly bureaucratic in that to pretend to know the asset allocation just prior to distribution is insane if greater than 5-10 years from retirement or distribution as no one would know what allocation would be prudent at that time. It would be a guess at best. Most people dont know what their financial situaion will be 6 months from now let alone 5, 10 or 25 years from now.
Just focus on costs first which most good planners and investment plans now do (ie American Funds etc).
If the bureaucrats/Congress really want to help they would first get the DOL, SEC, FINRA and CFP board to agree on what fiduciary really means. The rules right now are excruciatingly confusing and multiplicious. Secondly the financial industry needs to have education processes and designations such as CFP certifications that mean something and ban all the rest. Make them equate to the CPA and JD designations. The only two right now are the CFP and ChFc to a lesser extent.
Nannyism is not what people need and most financial planners I know do explain the target date funds to folks -they just choose not to listen.
But there is a real lack of expertise across the spectrum about true cohesive multi disciplined financial planning.