Subject: File No. S7-25-99
From: Catherine L. Robson, CFP

September 14, 2004

I work with the public as an independent financial planning professional who makes full disclosure of compensation, educational background and licensing, conflicts of interest, and disciplinary issues. There should not be a double standard for brokerage firms that allow stockbrokers to hold themselves out to the public as financial planners offering advice and charging for it “incidental” to their security sales. Some firms bring on clients by developing and charging for financial plans as a route to security sales. In my opinion, any individual who charges a fee for financial planning and also sells securities should not be exempt. Such advice cannot be incidental. Financial advice is developed for each client who has unique needs and issues. It is a thorough and detailed process that leads to recommendations and an action plan. The client’s best interests should always come first and be protected. To set up a double standard only undermines the trust we are trying so hard to develop with the public.

Catherine L. Robson, CFP