Subject: File No. 4-606
From: Clay Williams
Affiliation: Former CFP(r) Investment Advisor, Current Accounting Student

July 27, 2010

My comment is that I believe there is a large gap between the average investment advisor's perception of their fiduciary duty to clients and the client's perception of the advisor's duty to clients. Sales people at wire houses and other high turnover financial service shops should not be able to print "Investment Advisor" or "Financial Advisor" on their cards. They should only be able to print "Sales Associate" or something to that effect on their cards.

I was in the financial services industry for 10 years and have noticed that the current system is set up to award employees who have low moral standards. Employees that spend the time to educate themselves about personal finance and appropriate use of financial products are often ostracized. They are viewed by management and peers as being too analytical or difficult, when in fact they are knowledgeable and genuinely concerned with the financial well-being of clients. Yes, it is more difficult to sell a knowledgeable employee on the merits of a product that is difficult to understand and packed with opaque language and service fees. Nevertheless, these knowledgeable employees are providing all the service and advice to clients. Therefore, they have a vested interest in maintaining high standards of conduct in order to maintain the trust of clients.

The Certified Financial Planner (tm) designation needs to hold more clout with consumers. Currently many consumers are not aware of the tremendous amount of commitment it takes to achieve this designation. There are many designations available for financial service professional, however the CFP is the most comprehensive and most difficult one to achieve. I like to relate the CFP to the CPA designation. The majority of consumers would rather have a CPA do their taxes because they know that a CPA has the requisite knowledge to do a good job. Consumers should feel the same way about the CFP when it comes to getting investment, insurance, taxation, and estate planning advice.

In order to support the CFP designation, I purpose that the SEC and FINRA use funds from the fees and penalties gathered from financial services firms to promote the CFP.