Subject: File No. S7-25-99
From: Richard W L Hall
Affiliation: Past director Nm IAFP and FPA

January 15, 2005

My back ground is a developer and teacher of a Consumer Protection Financial Literacy course use nationally in New Zealand. I am a ChFC, CFP practitioner, RIA, Associate Chartered Accountant with Insurance lcioenses and Securities Principal.

I offer both completely fee only relationships with my cleitns as well as commision compensated programs.

The issue is not compensation but that the consumer clearerly understands the the qualification and relationship. Who is the individual responsible to, their company or the client.

Disclosures on pamphletes amongst the millions of other find print will not help at all.

Individuals should be required to show clearly on business cards, stationary, advertising either
BrokerSImple series 7 designation , Investment Advisor RIA , or Financial Advisor CFP, ChFC, or CPA with PFS.

Financial advior or Consultant imply a much broader range of advice than investment advice and the RIA examinatiosn cvertainly do not qualify a person to claim to be a financial advisor merely an investment advisor.

I became a CFP after already haivng a degree in finance and a ChFC because we need a nationally recognised designation such as MD or CPA for the public to rely on.

Ideally I would like CFP to be the only designation that entilesa person to decribe themselves as a Financial a advisor, consultant or planner but realistically one of the 3 CFP ChFC CPAPFS may need to be accepted.

When the large broker dealers advertise that they will help you reach your goals and stand by you they should be required to dosclose that this level of support is only offered by their representatives.

Investment advice incidental or otherwise should always require the RIA qualification. A broker is simply an transaction processor. RIA stands for Registered Investment Advisor, surely any one giving investment advice for any reason or purpose much that this designation .

There are too many in the field who are simply salesmen with their own interests at the fore and with little professional knowledge. The public needs to be made aware of those that are simply salesmen and those that are qualified to provide broad investment and financial advice and whose responisbility is to the consumer not the company.