Certified Financial Planner Board of Standards, Inc.

1235 Jefferson Davis Highway, Suite 602, Arlington, VA 22202
P:303-830-7500    F: 303-860-7388   E: govrelations@CFP-Board.org   W: www.CFP-Board.org

November 20, 2002

Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609

Re: Release No. 33-8138; File No. S7-40-02,Disclosure Required by Sections 404, 406, 407

Dear Mr. Katz:

I am writing to provide information on the Securities and Exchange Commission's (the Commission) proposal to require companies to include new disclosures in their Exchange Act filings. Specifically, CFP Board is commenting on the requirement that companies disclose the number and names of persons that the board of directors has determined to be the "financial experts" serving on the company's audit committee. The CFP Board1 appreciates this opportunity to provide information it hopes is helpful to the Commission.

CFP Board exists to provide consumers an indication of competency in personal financial planning. Therefore, CFP Board has a history of promoting standards in all fields where it will eventually affect consumers, specifically in financial services. CFP Board supports provisions that foster greater competency in public company audit committees.

Considering the uncertainties American's have faced over the last year, CFP Board believes the Commission should do whatever it can to ensure the investing public about the safety and soundness of America's financial markets. Requiring public companies to disclose whether at least one "financial expert" serves on the audit committee will help in this endeavor. CFP Board does not believe consumers will necessarily benefit by public companies automatically disclosing the names of the financial experts on the audit committee. If this information is made public upon request, consumers could obtain the information when they deem it necessary.

While investors may not frequently pay attention to any of the issues surrounding audit committee's financial experts, those that provide financial advice to them may do so more often. CFP Board believes financial planners and other financial services professionals will benefit as well from the Commission's proposed rules. Since a large number of investors rely on outside professional advice, the faith and trust financial planners and other financial services professionals have in particular public companies is as important as consumers themselves.

CFP Board is pleased the Commission has addressed the competency of those serving on public company's audit committees. If you should have any questions about CFP Board or the individuals it certifies, please contact me at 703-414-5814.


Michael Herndon
Director, Public and Government Affairs

1 Founded in 1985, Certified Financial Planner Board of Standards, Inc. (CFP Board) is a nonprofit professional regulatory organization that fosters professional standards in personal financial planning so that the public values, has access to and benefits from competent financial planning. CFP Board currently authorizes more than 40,000 individuals to use its marks in the United States and 16 international affiliates certify additional thousands of qualified persons in other countries. CFP Board also serves as an educational resource to federal and state lawmakers and regulators on personal financial planning issues.