Subject: File No. 4-606
From: James Daniel, CFP
Affiliation: Financial Planning Association, NAPFA

August 27, 2010

A fiduciary standard for those providing "advice" is paramount to restoring the faith and credibility in the retail financial services industry. Those calling themselves "financial advisors" or "financial planners" have to be truly independent and unassociated with particular companies and/or products.

There is and always will be a need for advisors that work for insurance companies or brokerages, but they should label themselves accordingly such as "insurance advisor" or "brokerage advisor". There will always remain a level of distrust in the eyes of the consumer if we don't quantify that a "financial advisor / planner" is a fiduciary that gives only objective advice.