Subject: File No. S7-06-04
From: Ken W. Partch
Affiliation: Professional Financial Planner

April 1, 2005

I have been a registered representive for 20 plus year. I welcome guild lines that encourage investment professionals to act more responsibly and personally strive to be as transparent as possible in all my sales presentations. In fact, quality and timely measures have been implemented in the past making transactions more transparent, which has cleaned up the playing field and encouraged investing by the investing public. Of recent though, I think additional regulation are more along the lines of a car with the emergency brake welded in the on position. I dont need to tell you that in this day and age when the President is telling all of us that Social Security is not the future, having witnessed tax law changes that actually encourages investors to put more in their IRAs 403bs etc, with the likes of catch-up provisions etc., It is a fact that people need to invest for their future at a greater rate than in the past. Everyone would have to agree with this statement. The investments markets need more people making greater deposits on an ongoing basis into their retirement accounts. And the regulators, while encouraging proper selling procedures, need not over burden the investment community with additional paperwork that in the long run only will be done to the detriment of investor not moving forward. These days my clients sign more disclosure documents then they ever have - that is not a bad thing. But we have gotten to so concerned with the documents themselves that the contents become secondary to the original intent that might not be what you wanted. I know our clients read all the documents we hand them but the question is; do all investors understand them? I do not know the answer to taht. what I beleive is that it is best that the broker deal community work with regulators you to find solutions to real problems not just those that fly in the face of real needs on the part of the investor. What we need is investment professionals who pursuing good business, those that can solve investors long term needs. We also need a balanced approach to investing and a balanced approached to regulation and transparency in transaction. Please extend your hand to us and we will work with you to help investors get the best advice and sound counsel on all investment products. Lets move the same side of the table. Thnak you for your time. I care about my industry and I care about my clients I serve.