Subject: File No. S7-25-99
From: John C Brown

August 26, 2004

Thank you for re-examining the issue of exempting Broker Dealers from the Investment Advisors Act of 1940 regarding Fee Based Brokerage Programs.

As we see it, the brokerage industry needs to decide if they are brokers, acting on behalf of vendors or advisors, acting on behalf of consumers. We conclude that both activities can be conducted in an ethical fashion. But why should there be rule exemptions when one profession crosses over into the other?

We request that the rule proposal be withdrawn

Colon Brown
Brown Brown Financial Services, Inc.