Subject: File No. S7-06-04
From: Paul R. Kiehn
Affiliation: Chartered FinancialConsultant

April 4, 2005

-We need more time to review these proposed changes. As proposed, these changes will make it very difficult and expensive for planners to have proper documentation at point of sale for all of the potential recommendations that we make. For example, last week in a client meeting out of town I had three different recommedations ready for the client depending upon the goals agreed upon during that meeting. If we had to use the proposed rules, it would have required an additional meeting to comply. This would create additional expense which would ultimately be born by the client.
Please rethink these proposed changes.