Subject: File No. 4-606
From: Scott Bombeck, CFP
Affiliation: President, Acanthus Associates

July 31, 2010

I have been a Financial Planner for 13 years and a CFP since 2003. None of the designations in our industry are viewed the same way as CPA's, JD's or MD's by the public. That is the uphill battle we face. The very first step is the adoption of an industry-wide fiduciary standard applied WITHOUT LOOPHOLES. This needs to be followed by a weeding out of the plethora of designations out there. There are just way too many designations with little to no public understanding of just what those letters mean. FINRA's website lists 94 professional designations. It is impossible for the public to put trust in a system that confusing. One might argue that there are at least that many areas of specialization in medicine. Yes, while there are a multitude of surgeons, obstetricians and other ologists, they are ALL DOCTORS in the public's eye. We need the same public understanding. Until we do we will be confined to the second tier of trust well above the schysters, but not quite a true "profession". The adoption of a level playing field through a universal fiduciary standard is the critical first step.