Subject: File No. S7-25-99
From: David W Cowles, CPA/CFP

August 25, 2004

Why should registered representatives charging an asset based fee be exempted from disclosing their conflicts of interest via Form ADV? Why is the public best served by two standards of conduct for persons providing financial planning services?

I am a registered investment advisor charging an asset based fee for financial planning services. If registered representatives are providing similar financial planning advice to the public and also charge an asset based fee, why arent their clients protected by the Investment Advisors Act of 1940 while mine are?

The Commission should WITHDRAW this proposed rule to protect the public and avoid giving one group of financial planning service providers a significant competitive advantage.