Subject: File No. S7-06-04
From: John F Robbins, MBA, CFP, CSA
Affiliation: FPA

April 1, 2005

Good Afternoon,

There is no question that the financial services industry has its share of bad apples. And if the piling on by the NASD and SEC in the form of additional disclosure, regulations and compliance over the past 15 years was doing anything to help the client, then I would have no problem with it. Unfortunately, the end result has done little or nothing to limit the bad apples from putting their own needs ahead of the client.

The current efforts are forcing the best advisors to work only with clients who have 250,000 to invest or more. Clients with less, which represent the vast majority of Americans, who need just as much help as anyone else, are left to fend for themselves or work with inexperienced advisors and/or the bad apples. Under my current setup, it costs 300 per year to keep a client file up to date. Add an hour of my time to meet with the client once a year and the cost climbs to 500. Clients who helped me get started and/or survive in the business can no longer afford to work with me. This isnt right. Nor is it right for me to continue helping them at a loss of both time and money.

Why not aggressively go after the bad apples? The wirehouses, insurance companies and/or independent broker/dealers know who they are. They see the paperwork every day. Why wait for a client complaint? Censure and/or prosecute them quickly and publicly. This will do more to clean up the industry than additional paperwork ever will. Many clients dont read what they are signing and never will. They resent all the additional paperwork just as much as we do.

It is my hope you will put a freeze on any new regulations or compliance until all the powers that be can determine what options are already available within the current system. More paperwork will continue to result in more lower and middle class Americans being left to plan their finances on their own.

How many experienced advisors are involved in developing new regulations and compliance for the industry? Many or most of the management within the wirehouses, insurance companies and/or independent broker dealers have never been in the field. Just like building a car, input from the drivers is just as important as the engineers designing them.

As an independent, we have little input with new broker dealer procedures and nothing with either the SEC or NASD. Yet, we are the ones out here trying to push all the piles being created. Financial planning is not rocket science. Why is it so complicated to develop a standardized financial profile with all the basic information needed to satisfy the regulations and compliance? Any advisor worth his or her salt uses the same procedure with every client initially. Why cant the industry he is working in do the same thing?

John F. Robbins, MBA, CFP, CSA
Trenton, MI