Subject: File No. S7-25-99
From: Harvie Roe, CFP
Affiliation: NAPFA

January 31, 2005

I have been a Fee-Only Financial Planner since 1982 and have seen a plethora of names used to describe the traditional broker. Most names were designed to confuse or present the person as having a broader purpose than to sell securities to the public. I urge the SEC to require everyone purporting to offer financial planning services to register as a Registered Investment Advisor. This will allow the public to better understand the qualifications, compensation, and the expertise of the person giving advice while confirming that a fiduciary relationship exists. Why is this so difficult? Please ignore the distractors who are claiming they are only offering advice that is incidental to selling or brokering securities, when they are clearly suggesting to the consumer much more. The terms people use to describe services should be consistent and have meaning to the consumer and every effort should be made to make this task easier.