Subject: File No. S7-25-99
From: Eric R Clarke
Affiliation: President, Orion Advisor Services, LLC

August 24, 2004

I would urge the SEC to withdraw, not amend, the rule proposal. I believes the rule is anti-competitive by creating two standards of conduct for persons offering financial planning services: one for registered investment advisers and one under NASD suitability rules and anti-consumer, by permitting non-disclosure of conflicts of interest by registered representatives. The Consumer Federation of America and AARP also strongly object to the rule.