Subject: File No. S7-25-99
From: Bertram B Unger, CFP
Affiliation: Adjunct, CFPr Education program, Barry Univ. Dir. of the Gold Coast Financial Planning Association

August 28, 2004

I believe the rule is harmful to consumers by creating two different standards of conduct for persons offering financial planning services: a higher fiduciary standard for registered investment advisers and a lower one under NASD suitability rules. The rule also exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.

A level playing field is the standard for most business in our country. Please consider this in your new review of the rule.


Bertram B. Unger, CFPr