Subject: File No. S7-25-99
From: Eben Halberstam

July 22, 2004

To whom it may concern:

I agree with The Washington Post's Michelle Singletary and the Financial Planning Association that File No. S7-25-99, Certain Broker-Dealers Deemed Not To Be Investment Advisers, would blur the line between who is and isn't an investment adviser. I join with Ms. Singletary in her disappointment that, given all the scandals in the investment brokerage industry, the Securities and Exchange Commission isn't aggressively pushing to have anybody who, incidentally or not, gives advice about securities be covered by the Investment Advisers Act of 1940. I agree that there should be a uniform set of rules for all the people portraying themselves as advisers. Please reconsider the proposed rule to require that anyone giving investment and financial advice to adhere the fiduciary standard of acting in the client's best interest.

Thank you for your consideration,

Eben Halberstam (
3903 Railroad Ave
Fairfax, VA 22030