Subject: File No. S7-25-99
From: Thomas G. McHale

September 10, 2004

To Whom It may Concern:

I recently read in the Wall Street journal that you are considering allowing "registered reps" who deal with investors on behalf of brokerage and other investment companies to refer to themselves as Financial Planners or Financial Consultants. As a long-term investor who has dealt with a large number of these individuals, I am very strongly against any such rule that would allow this to happen.

My personal experience is that these individuals or reps lack the knowledge and experience to be called Financial Planners and rarely have any concern for the overall financial posture, health or direction of individual investors. Furthermore, it is also my experience that very few have the background and training to know what the financial planning process should include and how to go about developing a comprehensive Financial Plan for the investor.

I also strongly believe that this is a step back to the days of the 1990's when speculation, bad advice and lack of objectivity, fueled by these same "reps", led many investors into bad investments.

Please, for the sake of the average investor, don't pass such a rule. Financial Planners should be just that - people experienced in the development of objective, solid advice and plans for investors who are building for retirement or other meaningful objectives. True Financial Planners, such as CFP's, need to be distinguished from "registered reps" or their equivalent. Thank you for the opportunity to comment.


Thomas G. McHale