Subject: File No. S7-25-99
From: Bernard M Kiely, CFP/CPA
Affiliation: FPA, AICPA NAPFA

September 2, 2004

I strongly believe that broker-dealers holding out as Investment Advisors SHOULD NOT be exempt from the Investment Advisers Act of 1940. If broker-dealers want to hold out as being like me they should be registered as I am.

Very truly yours,

Bernard M. Kiely, CPA, CFP
A NAPFA Registered Financial Advisor
Kiely Capital Management, Inc.
Morristown, NJ 07960
973 455-1894