Subject: File No. S7-25-99
From: Brian R. Smith, CFP

September 10, 2004

To whom it may concern:

I believe that people who hold themselves out as financial planners should have financial planning credentials. I hold the series 7 and insurance license and there is not an adequate amount of information that you are required to learn in preparing for these exams to qualify to do financial planning. I have been in the business for 14 years and I now am registered with an investment advisor and I am a CFP. Only recently have I started doing fee based financial planning and I do not believe I was qualified to do so early in my career. The rules that deal with tax-qualified plans, IRA's, distribution rules, HRA's, HSA's, Coverdell IRA's, 529 plans etc. are very complex and are a big part of planning. It goes beyond simple asset allocation and an understanding of options. In fact much of what is required knowledge to pass the series 7 does not apply in most cases for a financial planning client. With the new "ownership society" that President Bush keeps referring to, risk is being shifted from the government and corporate America to the individual. UAL and Delta are in trouble with their pension plans as we speak. It is getting more and more important for people to seek good advice. With that said there are only 31,000 CFPs in the US right now. Only 300 in my state of Alabama. More people would go to the trouble to get proper education and credentials if it was required. I do not understand the huge debate by people who are not credentialed that are fighting the push by the FPA to have standardizing in the industry so the public has a standard to go by. If all of these un-credentialed people and people not registered under the advisors act are as professional and competent as they say they are why cannot they just go take a couple of exams, have credentials and get on with it. I think the answer is they cannot pass the exams and they are too lazy to prepare for them. I think given the increasing need for people to have good advice something needs to be done to regulate this better.


Brian R. Smith, CFP