Subject: File No. S7-25-99
From: Jacqueline J Goldberg, CPA
Affiliation: CEO, Arthur Financial Service, Inc.

August 23, 2004

Please withdraw the rule exempting broker-dealers from the Investment Advisors Act of 1940 where it concerns fee based brokerage programs. Broker-dealers should be held to the same standards as other financial professionals. Also, they should be required to disclose conflicts of interest