Request for the Commission to Amend Rule 206(4)-1(a)(1) under the Investment Advisers Act of 1940 Concerning the Use of Testimonials by Investment Advisers Who Are Also Planners

[File No. 4-489]

From: Chris Grande
Sent: Friday, October 03, 2003 5:30 PM
To: rule-comments@sec.gov
Subject: use of testimonials by an IAR who is also a planner?

Hi,

I'd like to comment on rule 206(4)-1a1 concerning
testimonials used by advisors.

I am a small practice financial planner appointed as
an IAR - and the rule prohibits me from using
testimonials with my planner clients because of my IAR
designation. I would like to see a ruling allowing a
planner to use non-performance based testimonials with
prospective clients.

For example, I got, just this week, 2 mail offers: one
from an options report, and one from a currency report
telling me about the spectacular returns i could get-
and both reports were accompanied by testimonials -
now I assume that both of these newsletter reports are
exceptions to the Act but still, they can promise
that, but an advisor cant offer testimonials on such
things as how diligent they are, how much service they
provide, the overall quality of the client experience.

I think that disallowing testimonials based on
performance for advisors is admirable, and correct.
however, the restriction placed on planners who happen
to also be advisors is limiting because their practice
encompasses the overall client relationship and not
just investment performance.

In summary, I would like to see considered a follow up
ruling concerning planners who also are advisors and
their use of testimonials not based on financial
performance -specifically, to find some way to allow
that and allow us the same ability to use them as an
RR has.

thank you for your time.

warmly,

Chris Grande

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Walnut Hill Advisors
407R Mystic Avenue - 34C
Medford, MA 02155
781.393.0021 (phone)
781.391.4125 (fax)
www.walnuthilladvisors.com