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Certified Financial Planner Board of Standards 
1700 Broadway   Suite 2100
Denver, Colorado 80290-2101
303/830-7500   Fax:  303/860-7388

February 10, 1997


Mr. Jonathan G. Katz
Secretary
Securities and Exchange Commission
450 Fifth Street NW, Stop 6-9
Washington DC 20549

Dear Mr. Katz:

Subject: Comments on Proposed Rules Implementing Amendments to the   
Investment Advisers Act of 1940, Release No. IA-1601, File No. S7-31-969

The Certified Financial Planner Board of Standards, Inc. (CFP Board) is a   
voluntary standards-setting, credentialling, marks licensing and   
disciplinary body organized to act in the public interest in regulating   
those who seek for and maintain our certification.  Our federally   
registered marks CERTIFIED FINANCIAL PLANNER and CFP are the most widely   
recognized designations in the field of financial planning.  More than 90   
U.S. colleges and university programs have adopted our model financial   
planning curriculum as the standard for their coursework for students at   
the undergraduate, graduate, and certificate levels.  Our two-day   
certification examination is similar in concept to the bar or CPA   
examination, and includes significant material on investment planning,   
retirement planning and other subjects closely related to investment   
advice regulated by the SEC and the state securities agencies.  Exam   
applicants are expected to number about 4,500 in 1997, and more than   
30,000 persons are currently certified with us; the vast majority of our   
CFP licensees are associated with firms, or are individually, registered   
with the SEC and with one or more state securities agencies.  Given our   
work in financial planning, including investment advising, during the   
last decade, we care deeply about the new federal securities legislation   
and the implementing regulations.  Prior to our receipt of the proposed   
regulations, we would have estimated that under the Investment Advisers   
Supervision Coordination Act of 1996 about one-third of those persons   
providing investment advice that we have certified would be working with   
firms registered with the SEC and about two-thirds would be associated   
with firms registered with the States.  The combined effects of the   
proposed regulations as we understand them, however, seem likely to   
result in a much more even distribution of those persons we have   
certified or will certify in the future.

We recognize the difficult job that the Division of Investment Management   
had in proposing rules implementing the Investment Adviser Supervision   
Coordination Act in so short a period of time.  We commend the Commission   
for its timeliness and for the generally helpful draft regulations that   
the CFP Board believes have gone a long way toward clarifying issues left   
unresolved by the legislation itself.  We express our appreciation to the   
Division of Investment Management for the good work preceding these   
proposed regulations. While the proposed rules overall are good, we   
recommend some specific changes.


I.  SUMMARY

Fuller explanations of comments on specific sections are found letter in   
this letter, but highlights include:

Clarifying the "continuous and regular supervisory or management   
services" requirement;
Revising the exemptions from prohibition on registration with the   
Commission;
Substituting the term "licensing" for "registration" for clarification in   
final regulations when referring to investment adviser representatives;
Defining the term "investment adviser representative" in final   
regulations in a manner that states can embrace so there is uniform use   
of that terminology for both SEC and state registered investment adviser   
representatives, thereby benefiting both the public and advisers;
Recognizing the growing need for professionalism in investment advising,   
and the specific need for appropriate qualifications for investment   
adviser representatives, in order to protect the economic health and   
well-being of investors and consumers;
Removing unintended regulatory biases providing marketplace competitive   
advantages to certain investment advisers over others; and
Anticipating and planning for significant investment adviser registration   
changes and oversight responsibilities by both the SEC and state   
securities agencies after implementation of the final regulations.



II. CONTINUOUS AND REGULAR SUPERVISORY OR MANAGEMENT SERVICES

In order to determine whether a specific investment adviser should be   
registered with the SEC or with the States, Section 203(A)(a)(2) of the   
Investment Advisers Act defines "assets under management" as the   
"securities portfolios with respect to which an investment adviser   
provides continuous and regular supervisory or management services."   
 Although the examples provided in Form ADV-T are not unhelpful, they do   
not cover the gradation of services that investment advisory and   
financial planning firms provide in the marketplace today.  Moreover,   
this approach places the burden on an applicant to decipher which side of   
an unclear or "crooked, broken-line" demarcating the jurisdiction between   
the SEC and the States it is on.  The preferable approach would be to ask   
several more specific questions on the proposed form of all investment   
adviser applicants, and thus provide the SEC a basis for determining   
whether or not an applicant properly qualifies to be an investment   
adviser registered with the SEC.  For example, questions on the form   
could determine whether the investment adviser performs supervisory   
services, management services, has discretionary authority, etc.  These   
terms themselves might have to be defined in the final regulations so   
that the SEC has some concrete information with which to work in such   
registrations.  The difference between "periodic" and "continuous" could   
be defined on the form in lucid terms to applicants.  It would then be   
clear to any applicant that a registration that has all "No" boxes   
checked will not result in SEC registration, unless the applicant   
qualifies through one of the exempted categories being proposed by the   
SEC.


III.  TRANSITIONS BETWEEN STATE AND COMMISSION REGISTRATION

It is clear that there will be both transition and migration of   
investment advisers between SEC and state registration.  In order to   
minimize the potential for investment advisers to avoid registration,   
even for a time, as a result of this process (whereby one regulator   
mistakenly believes that another regulator has primary responsibility),   
we recommend that information about registration/de-registration status   
be routinely shared among regulators and that this information be made   
available to the public either by telephone or other electronic means.


IV. EXEMPTIONS FROM PROHIBITION ON REGISTRATION WITH THE COMMISSION

The CFP Board assumption is that there will be fewer regulatory hurdles   
and burdens for investment advisers under SEC registration than under   
state registration.  Accordingly, we assume that there will be economic   
and other pressures to induce investment advisers to find ways in which   
they could secure SEC registration as opposed to registration with one or   
more individual state securities agencies.  The SEC is proposing to   
exempt advisers from the prohibition on Commission registration in four   
cases.

The CFP Board supports the proposal to have the SEC register "nationally   
recognized statistical rating organizations," and "investment advisers   
with reasonable expectation of eligibility."  However, we are concerned   
about conferring a similar status on "pension consultants" and "certain   
affiliated investment advisers."  In the case of both "pension   
consultants" and "affiliated investment advisers" there would appear to   
be consumer marketplace inequities and perhaps anti-competitive effects   
to what is being proposed.  We do not wish to minimize in any way the   
value of pension consulting, but we do not understand why there is any   
different standard for assets under management for "pension consultants"   
than there is for other investment advisers.  Specifically, the   
Commission is prepared to allow SEC registration for pension consultants   
who provide advisory services to fiduciaries of pension plans, but who do   
not actively advise with respect to the assets under management of such   
plans.  If SEC registration is appropriate in these cases, why would it   
not be appropriate when it comes to investment advisers that provide   
similar services to other entities of such major assets?  We urge the SEC   
to either drop this exemption entirely, or provide a similar exemption   
for every other type of consultant so long as the investment adviser   
consultant provides "investment advisory services in selecting and   
monitoring investment advisers that manage assets of such plans" to any   
entity having assets the aggregate value of which is at least the same   
dollar figure established for "pension consultants" during the last   
fiscal year.  Without such a level-playing field requirement, state   
registered investment advisers will simply add pension consulting or   
increase their existing pension consulting activities to the proposed $50   
million in order to become SEC registered.  In short, there is nothing   
unique about "pension consultants" for them to be classified differently   
than all other investment advisers.  All investment advisers have an   
effect on national markets.  In terms of what dollar level, if any, for   
all investment advisers would be appropriate, we urge you to contact Dr.   
Jeff Turner at the U.S. Department of Labor who we believe could give you   
data to help you understand the numbers and sizes of employee benefit   
plans discussed in this section.  You might also wish to review the   
research of Greenwich Associates in this context.

We have similar concerns about the exemption for certain affiliated   
investment advisers.  We suspect that investment advisers who wish to be   
registered with the SEC will seek affiliation with existing investment   
advisers in order to secure this exemption from prohibition on   
registration with the SEC.  While there may be some comfort that this   
exemption will only be available if the principal office and place of   
business of the adviser is the same as that of the affiliated registered   
adviser, it still provides what appears to be a significant hole through   
which to secure SEC registration and gain competitive advantages.  We   
gather that the argument for such a proposed exemption from state   
registration is a "no increase in administrative burden for the SEC   
concept," but there does not seem to be any compelling public policy   
argument from the standpoint of the investor or consumer.  In fact, there   
may be consumer or investor harm to the SEC registration, if there is not   
proper alignment between the SEC and the States on individual investment   
adviser representative licensing, as dealt with later in this letter.

We do not believe either of these proposed exemptions meet the test set   
forth in Section 203(c) of the Act.

V.  INVESTMENT ADVISERS NOT REGULATED OR REQUIRED TO BE REGULATED BY THE   
STATES

We commend and strongly support the proposed SEC interpretation that   
would require all investment advisers to be regulated either by the SEC   
or by the States, except for advisers that are exempt from registration   
under both the Investment Advisers Act of 1940 and the individual state   
statutes.  This is the proper public policy result, provides the greatest   
level of protection to consumers and investors, and is the most fair for   
investment advisers.  We hope that in the future the policy will lead to   
reductions in exemptions and exceptions from state to state for such   
registration of investment advisers.


VI.  PERSONS WHO ACT ON BEHALF OF INVESTMENT ADVISERS

There appears to be some confusion of language in the proposed rules and   
we strongly recommend that it be corrected in any final publication of   
SEC regulations.  Specifically, there is a confusion and misuse of the   
terms "registration" and "register" with the terms "licensing" and   
"license."  Credentialling is a generic term for licensure,   
certification, and registration.  Licensing is a process by which a   
government agency grants individuals permission to engage in a specified   
profession or occupation upon finding that individual applicants have   
attained the minimal degree of competency required to ensure that the   
public's health, safety, or economic well-being will be reasonably well   
protected.  Certification is the process by which a governmental or   
non-governmental organization grants authority to use a specified title   
to an individual who has met predetermined qualifications. The vast   
majority of certification has been traditionally, and is presently,   
performed by private, non-profit, voluntary organizations.  The primary   
purpose of licensure and certification is to protect the public.   
 Registration is the least restrictive form of regulation, usually   
consisting of requiring individuals to file their name, address and   
qualifications with a government agency before practicing the profession.   
Examples of how use of the corrected language would read in the proposed   
rules follow:
"Thus, the definition of supervised person parallels the traditional   
Commission's view that persons performing advisory services on behalf of   
an adviser are not required to separately register be individually   
licensed."  We don't believe that this corrected statement is or ought to   
be the Commission's view; we note Commissioner Steven M. H. Wallman's   
testimony of  June 4, 1996 to the Senate Banking Committee on S. 1815,   
for example, "that investment adviser employees who provide point of sale   
advice to retail customers [should] meet the highest level of   
professionalism and satisfy appropriate testing, educational or other   
standards" and noting that "The Commission itself has no such   
requirements."
"The term, therefore, would exclude (and, thereby preclude states from   
registering licensing) supervised persons who provide advice to   
investment companies . . ."
"The Commission notes that persons not falling within the definition of   
'investment adviser representative,' while not subject to state   
registrationlicensing and qualification standards, would not be   
'unregulated.'"  The CFP Board believes it is obvious that they would be   
individually unregulated.  Moreover, Commissioner Wallman in his   
testimony noted that "investor protection may be harmed" with such an   
approach.
Similarly, under the section entitled "Place of Business" another   
statement:  "Under Section 203A(b)(1)(A) of Proposed Rule 203A-3(b), an   
investment adviser representative may be required to register be licensed   
in multiple states if the adviser representative has multiple places of   
business."
"This provision is designed to prevent itinerant investment adviser   
representatives from claiming they have no place of business and are thus   
not subject to any state's registrationlicensing or qualification   
requirements."

These revised or corrected statements in the proposed regulation make   
clear use of such terms of such as "registering" and "licensing" and thus   
permit the public and others to better understand what the SEC and state   
securities agency policy generally is at present, and is moving toward in   
the future.  In short, use of these widely accepted terms throughout   
government regulation helps illustrate how we are transitioning rapidly   
toward a more traditional regulatory framework of individual professional   
licensing for purposes of financial planning and investment advice.


VII.  INVESTMENT ADVISER REPRESENTATIVE

The single most important change that needs to be made in the proposed   
regulations concerns the definition of "investment adviser   
representative."  We agree with the SEC about the advisability of having   
a uniform national definition of the term "investment adviser   
representative."  After all, the theme of uniformity is one which   
underlies the Investment Adviser Supervision Coordination Act of 1996.   
 We are uncomfortable with each individual state defining that term   
differently.  Such an outcome would be undesirable, both from the   
standpoint of the financial planning and investment advisory communities,   
and for consumers and investors throughout the United States and abroad.

However, we believe that the definition proposed in the regulations is so   
different from the NASAA Uniform Securities Act, as amended, as to   
virtually guarantee a lack of uniformity between state investment adviser   
registration requirements and SEC investment adviser registration   
requirements for firms having investment adviser representatives.  We   
strongly urge the SEC and NASAA to develop language that both levels of   
government can support, and sustain a national uniform definition of this   
term.  In order to get there it would appear appropriate to start with   
the NASAA definition as the departure point, since it was that   
terminology that was in existence when the Congress determined to include   
this terminology in the Act passed in 1996.  Moreover, it was this   
agreement on the terminology of "investment adviser representative" that   
broke the Congressional logjam and allowed the legislation to be enacted   
in the first place.

There has been a long history over several sessions of Congress that   
established the need for qualification standards for investment adviser   
representatives.  In general, the thrust of such testimony was to protect   
individual or retail investors as the proposed regulations indicate.  But   
the regulatory concern was not confined to just these groups.  For   
example, lack of qualifications would affect local businesses as well, as   
investment advisers are turned to increasingly by persons of all levels   
of sophistication and awareness.  House Report 103-75 on April 29, 1993,   
for example, stated that: "Because of the exponential growth in the   
industry [financial planning and investment advising] and its relative   
lack of regulation, the opportunity for clients of all sizes and levels   
of sophistication to be harmed is significant."

The CFP Board supports appropriate qualifications for investment adviser   
representatives, no matter to whom they provide advice and no matter with   
which entity*the SEC or the state securities agencies--they are   
registered.  After all, we don't as a matter of public policy say that we   
shouldn't have to license physicians if they give medical advice to   
wealthy patients or to healthy patients, but we do require licensing if   
they treat poor or sick patients.  The U.S. Department of Health and   
Human Services does not preempt physicians from having to be individually   
licensed by the States if they are employed by large businesses, but   
require them to be state licensed if they give middle class or lower   
economic class individuals medical advice.  Neither would we tolerate   
federal preemption of state architect licensing statutes for architects   
who work on large buildings, large apartment complexes, or who serve   
wealthy homeowners, but permit or require architect state licensing for   
the construction of mid-range or small houses, or for those architects   
who serve those of lesser economic means.  The whole concept of the   
Federal government prohibiting application of individual qualification   
standards and licensing for physicians and architects and others is   
harmful to the public health and safety and just plain ludicrous.  It is   
similarly inimical to the public's economic health and safety to prohibit   
state licensing statutes reaching all investment adviser representatives   
who purport to serve the financial health and safety of millions of   
American citizens.  Accordingly, we strongly urge that the Commission   
throw out the "substantial portion" test being proposed and the "natural   
person" test being proposed in the draft regulations.  All investment   
adviser representatives should meet the same qualification standards that   
the states set for persons offering investment advice.  We note that   
Commissioner Wallman also spoke to this same concept in his June 4, 1996   
testimony wherein he said that the premise "that larger firms have good   
procedures for maintaining a quality workforce, while smaller firms do   
not . . . is not supported by any evidence or theory, and may be   
interpreted to demean and harm the reputation of small businesses" and   
really "inadvertently harm small business."

The proposed regulations state that "The Commission notes that persons   
not falling within the definition of 'investment adviser representative,'   
while not subject to state registration and qualification standards,   
would not be unregulated."  The CFP Board believes this statement to be   
false.  While the firm would be regulated, the individual would not be   
regulated or subject to the same kind of state licensing and   
qualifications program that everybody else would be subject to in a given   
state.  To propose preemption of individual qualifications criteria to   
protect the public is misguided public policy.  As Commissioner Wallman   
noted in an earlier statement, such a policy would have anti-competitive   
effects.  For example, an associated person employed by a large firm who   
sought to change jobs and work for a smaller firm would have to comply   
with state licensing statutes, and this might be a barrier to such a   
move.  Further, larger firms registered with the SEC would have an   
advantage in recruiting, since individuals joining them would not have to   
satisfy any state requirements purposely set up to protect the public   
through minimum standards.  Under the statutory scheme envisioned by   
Congress in passing this Act, it is the individual states that are to   
regulate the qualifications of individuals in the fields of investment   
advice and financial planning, and the business of firms performing   
investment advisory and financial planning work--and which governmental   
entity the firm would register with--would generally be based on the size   
of the firm.  This is consistent with the historic role of the States in   
engaging in occupational and professional licensing in many fields.  We   
do not believe that the Congress ever intended that the SEC give one   
segment of the industry a competitive advantage over another.  Under that   
statutory division of responsibilities in the legislation, we believe the   
SEC should let the States do a proper job of individual licensing, and   
support them in acting appropriately.  That is why we urge the SEC to   
begin with the investment adviser representative definition provided by   
NASAA, and then work cooperatively with NASAA to secure agreement for any   
changes, so that we have a uniform definition nationally.  The CFP Board   
is willing to help in this important process.

Taking any other course than working with the States on a common and   
uniform definition will raise an important public policy question in the   
very near future for the SEC.  The SEC had stated that there are   
essentially no qualification requirements for SEC investment advisers.   
 House Report 103-75 notes that "the Commission does not evaluate adviser   
competence" and further explains that it has been the States that have   
compensated "for what are perceived as gaps in the federal law" such as   
requiring the licensing of investment adviser representatives and   
competency screening of those representatives.  With the announcement by   
NASAA in May 1996 that it intends to develop a competency examination for   
investment adviser representatives, any preemptions by the SEC of state   
investment adviser representative licensing and qualifications for   
personnel with SEC registered investment adviser firms will put   
additional focus on this SEC shortcoming, and perhaps place the SEC in   
the position of establishing some federal competency qualifications or   
explain why SEC registered firms may employ or use "unqualified"   
personnel in working with investors and consumers.  The best approach   
would seem to be to work now with NASAA and others to determine what   
personnel of investment advisers working with investors and consumers   
should be under competency and other qualifications requirements to go   
into effect shortly for both SEC and state registered investment adviser   
firms.  Taking this approach would eliminate the perceived inequities and   
competitive advantages that SEC registered investment advisers would   
have.

The SEC has also requested specific comment on the question of whether   
"an investment adviser representative that is dually-registered as a   
broker-dealer agent in a state [should] be excepted from the definition   
of 'investment adviser representative?' "  We point out that neither the   
proposed regulations nor the legislative history of the Act provides any   
real background needed for this question to be posed.  Nonetheless, we   
comment by using another analogy -- that of states licensing both   
pharmacists and physicians.  Both physicians and pharmacists are   
important, of course, for the health and well-being of the public, but we   
know of no one who believes that it would be appropriate for the health   
and safety of the public for pharmacists to be able to act as physicians   
without first having to complete the state-set qualifications --   
education, examination, experience, etc. -- necessary to actually be   
judged capable to engage in the practice of medicine with human beings.   
 Just as it would be imprudent to have persons with only pharmacy   
training -- permitting them to fulfill prescriptions written by   
physicians -- to act generally as physicians, so it would be unwise and   
improvident to have stockbrokers serve as investment adviser   
representatives or financial planning practitioners without education,   
examination or other qualifications first being met.  There is a huge   
difference in being licensed as a securities salesperson versus one   
capable to provide competent investment advice or overall financial   
advice to individuals, families or others.  Further, there is a clear   
difference in duties owed by registered representatives and investment   
advisers; the former have a primary duty they owe to the principal, the   
broker-dealer, whereas an investment adviser has a fiduciary   
responsibility to the client that is primary.  In conclusion, there   
should be no exception for registered representatives from having to be   
licensed as investment adviser representatives.  Instead, such personnel   
may seek to become investment adviser representatives just like others by   
meeting the necessary qualifications set by the States and assuming the   
duty to serve the interests of the client first.


VIII.  PLACE OF BUSINESS

The CFP Board supports the SEC proposal that a place of business is any   
"place or office from which the investment adviser representative   
regularly provides advisory services or otherwise solicits, meets with,   
or communicates to clients."  It should be a physical location   
requirement in order for "place of business" not to become "doing   
business."  The idea of a "hotel room" or "client residence," however,   
being a place of business appears to be reaching and should be stricken.   
 Instead, an investment adviser representative should be required to have   
at least one place of business location in some state.  Without such a   
designated location in at least one state, there would appear an intent   
to evade regulation, and the test of a hotel room or a client's residence   
could then be brought into play.  Even if State B is not licensing the   
investment adviser representative because the adviser doesn't have a   
physical location of business in that state, that same investment adviser   
would still be licensed by State A because the adviser would have to have   
a place of business somewhere.  Such an approach to regulation by the SEC   
would encourage states to work cooperatively with the other states; we   
think this would be a good public policy result and provide greater   
uniformity, an important theme under the Investment Advisers Supervision   
Coordination Act.


IX.  SOLICITORS

The CFP Board agrees with the Commission's view that the Investment   
Advisers Supervision and Coordination Act of 1996 does not generally   
preempt state regulation of a solicitor for a commission registered   
adviser under the national de minimis standard.


X.  NATIONAL DE MINIMIS STANDARD

The CFP Board agrees with the Commission's conclusion that individual   
states may have a higher threshold, but not a lower threshold, than the   
national de minimis standard of five clients for an investment adviser.   
 There is no de minimis standard for investment adviser representatives.   
   


The CFP Board, on May 19, 1996, adopted a definition of "client" for use   
in financial planning by our many thousands of Certified Financial   
Planner licensees.  "Client denotes a person, persons, or entity for whom   
professional services are rendered.  Where the services of the   
practitioner are provided to an entity (corporation, trust, partnership,   
estate, etc.), the client is the entity, acting through its legally   
authorized representative."  It appears to us that the SEC proposed   
definition of "client" is consistent with one we have already adopted.   
 The CFP Board agrees that the SEC should adopt a definition of client   
for both sections 203(b)(3) and 222(d).  Clients should include foreign   
clients, but a foreign client should not be counted as one of those   
toward the national de minimis standard under this section in which the   
question is raised.



XI. CONCLUSIONS

Balance in several major areas will be critical for any final   
regulations.  Given the way the proposed regulations have been proposed   
for public comment, it seems entirely possible and likely that the SEC   
will end up with a good deal larger number of the 22,500 investment   
advisers under SEC registration than the 6,300 the SEC actually expects   
to retain.  This is because the burdens of SEC registration will be   
inherently lighter than the burdens of state registration (and more   
likely multi-state registration) for investment advisers, and the   
benefits like nationwide operation correspondingly greater, so that most   
investment advisers will use opportunities available to them to properly   
seek SEC registration.  These opportunities will include increasing their   
"assets under management" to $25 million or more, providing pension   
consulting to employee benefit plans of more than $50 million, or   
becoming affiliated with an SEC registered investment adviser.

Moreover, an approach taken by the SEC that constricts the application of   
the term investment adviser representative for investment advisers   
registered with the SEC -- such as using a "natural person test," "a   
substantial portion test," or excepting registered representatives of   
broker-dealers -- will only exacerbate the difference in both benefits   
and burdens between SEC registration and state registration.  Perhaps   
without intending it, the SEC may find itself artificially influencing   
the competitive marketplace positions of small versus large investment   
advisory and financial planning firms, small firms offering pension   
consulting versus those not doing so, and companies required to employ   
qualified and competent investment advisers versus those that are not so   
required, etc.  It is primarily for these and other public policy reasons   
that we urge the Commission to make selected changes in the proposed   
regulations, based upon our decade or more of experience with financial   
planning, including investment advice*the same decade that has seen such   
a large increase in investment adviser registration with the SEC and the   
States.

We believe that without a balanced approach in a number of these   
sensitive areas of proposed regulation the SEC, if it wishes to maintain   
its proposed expanded investment adviser jurisdiction, will need a large   
increase in staffing and resources to maintain that jurisdiction.  If, on   
the other hand, the SEC wishes to maintain its approximately 28 percent   
estimate of all future federal-state investment adviser registrations, it   
will quickly find itself having to use its Section 203(A)(a)(1)(a)   
discretion to increase the $25 million amount to something much higher,   
and this in turn would set off additional procedures involving   
de-registration and state registration for investment advisers then   
registered with the Commission.  These are among the reasons why broad   
definitions applying to both SEC and state registered investment advisers   
are needed up-front before the April 9, 1997 implementation date becomes   
effective.

Thank you for the invitation to comment on these proposed regulations.   
 We would be pleased to respond to questions that you may have about   
these comments.

      Sincerely,



      Robert P. Goss, CFP
      President