Subject: File No. S7-25-99
From: Kenneth F Robinson, JD, CFPtm
Affiliation: Owner, Practical Financial Planning

February 1, 2005

The proposed rule should be withdrawn.

Broker/dealers execute arms-length transactions with buyers in a caveat emptor setting. They get paid only when they persuade someone to buy or sell.

The financial planning relationship is fiduciary in its nature. Broker/dealers are not.

Allowing them to hold themselves out as providing financial plans even in any de minimis or incidental way without the appropriate licensing, puts the public at risk.

Financial plans should be created, guided, and carried out in a partnership between the individual and a fiduciary acting in their best interest. These plans do not always involve investments, and knowledge of investments is but one component of a responsible financial plan.

A plan that takes hours to complete and weeks to carry out, by definition, cannot be solely incidental to an investment-sales relationship.

Thank you.

Kenneth F. Robinson, JD, CFPtm
Financial Planning Association FPA
Alliance of Cambridge Advisors ACA
National Association of Personal Financial Advisors NAPFA
Ohio State Bar Association OSBA