March 31, 2005

Joseph Hall
Managing Executive for Policy
Securities and Exchange Commission
450 5th Street NW
Washington, DC 20549

Dear Joseph:

Enclosed please find a copy of Prudent Investment Practices - A Handbook for Investment Fiduciaries. Please let me know if you would also like an electronic version of the Handbook and we will be happy to provide you with one. Also enclosed is the companion publication Legal Memorandums for Prudent Investment Practices.

Among the 340,000 members of the AICPA are registered investment advisors, personal financial planners, and CPAs employed by broker-dealers. The PFP Executive Committee of the AICPA supports nearly 80,000 CPAs who provide investment services as part of their brokerage, financial planning, investment advisory or tax practices. The Committee determines technical policies regarding personal financial planning and serves as the official representative on those matters. The Committee also is an advocate for fiduciary responsibility practices of financial planners and investment advisers and actively works with many government agencies and organizations in the development of public interest programs.

We would like to thank you again for the opportunity of the meeting in Washington, DC and our ability to discuss the re-proposed rule Certain Broker-Dealers Deemed Not to be Investment Advisers.

If you have any questions or need additional information please contact me at 201-938-3555 or


Anat Kendal
Financial Planning