Subject: File No. S7-25-99
From: Stephanie A Gelfeld, MBA
Affiliation: Owner, Accountable Financial Group, LLC

January 17, 2005

You will be doing the American public a huge dis-service if you continue to allow broker-dealer reps to market themselves as financial planners. The far majority of them do not disclose the fact that their financial plans are simply manipulative tools to sell their firms securities and/or insurance policies.

You must put investors above all else. Part of this responsibility should be to require brokers to fully explain their compensation to investors UP FRONT. A broker-dealer who offers financial planning services or investment management services should also be required to tell investors about his limitations. If his advice is limited to the securities he sells, he should not be allowed to call himself a financial planner/advisor. He is, in fact, a securities salesman.

Every client that I have gained since I started my fee-only financial planning business has been lied to by securities salespeople who disguised themselves as financial planners/advisors. While this has been great for my business because it has been easy to get clients, I think it is a very sad statement about our financial system. The average consumer of financial services should be told up front exactly what a real financial planner does and how that person is compensated. This is an area of full disclosure that is not being met.