Subject: File No. 4-606
From: Thomas A Gore, CFP(r)

August 25, 2010

I wish to thank the SEC for their work on this important matter.

I have been practicing as a Financial Planner for 8 years. However, I began my working out of college as a registered rep 10 years ago. I was recruited to be a 'Financial Advisor' by an individual registered with a B/D - it wasn't even close, I was a sales rep for the B/D and affiliated insurance company. Even thought his was a horrible experience for me, it was the best thing to ever happen to me - I learned how to do business the wrong way. I was told to sell mutual funds, insurance, annuities, etc. I wanted to focus on helping people, but I had to help the company if I wanted to make money. At one point I was told to sell more annuities or my 'career contract' would be revoked.

Consumers are absolutely clueless when it comes to financial planning and management. A parallel is consumers and taxes. They are trusting people who get paid by selling them something vs. getting paid for their advice. It is my opinion that all compensation must be disclosed so sales people can't hide their compensation to most consumers that don't know how to find it. There may be a place in this world for commission sales for those who may not pay a fee for good advice, but those people don't really need investment advice yet, they need advice on debt, cash flow, taxes, etc., which a salesperson is not going to give them as they won't get paid for it anyway.

Disclosure is a must. Anyone whose compensation is commission shouldn't be able to call themselves an advisor or planner, it should be sales rep. Another identification problem is those investment advisors calling themselves financial planners and not providing planning advice. This needs to be disclosed as well.

This can be very easy. Require titles to be based on how you get paid and what you get paid for. For example, if you provide comprehensive planning advice, you're a financial planner. If you get paid for selling mutual funds and stocks, you're a sales rep, or broker. If you get paid for selling insurance, you're an insurance agent. If you provide investment management, youre an investment advisor. (Regulation can be categorized this way as well.) Make it easy for consumers to help themselves.