Subject: File No. S7-25-99
From: William C Jerome, CFP
Affiliation: RIA, member of NAPFA

February 2, 2005

The media and advertising arenas are full of brokerage houses claiming to be Financial Advisors, Wealth Managers, Financial Planners, and the like. Many of the large brokerage houses are pushing their salespeople to get the CFP designation and the professional image associated with it. Most people believe that stock brokers already have a fiduciary responsibility to their clients see the survey, TD Waterhouse and are shocked to discover that this is not true.

So, what we have here is a defining moment for the SEC.
Are you going to take the obvious, appropriate action, and require EVERY purveyor of product to be held to a fiduciary standard, or are you going to drop the ball AGAIN, and issue some kind of unenforceable sometimes, its ok type of ruling, thereby siding against the consumer and making your existence irrelevant? Because if you FAIL to make the correct move here, the public outcry for shutting down the SEC and replacing them with some pro-consumer agency will be loud.

Besides, wouldnt it be nice to be AHEAD of Elliott Spitzer for a change?

William C. Jerome