Subject: File No. S7-25-99
From: John W. Fiege
Affiliation: President, Financial Solutions, Registered Investment Advisor

January 15, 2005

Dear Ladies and Gentlemen,

Brokers do not have a fiduciary responsibility to their clients as do registered investment advisors. How can they not be held to the higher disclosure standards of a registered investment adviser in order to give the consumer a fair understanding of their true nature?

I know there are a percentage of wonderful brokers who also perform top-notch planning, but many dont. I have seen so many clients advised about their retirement portfolio in fifteen minutes it makes me ill. I have reviewed many broker-chosen portfolios so many just havent made sense. Poor products with high fees are chosen too often. Expensive annuities are selected for inappropriate customers. Simple, quality funds with low expenses are generally avoided. Reviews are not conducted unless the customer requests them. Funds are split between A shares and B shares. Sometimes B shares are chosen exclusively when A shares would have saved the client many dollars.

For those brokers who do plan well, wouldnt they be happy to disclose what they do and how they do it, just as registered investment advisors do?

This seems to me the only right thing to do to give consumers fair disclosure. Most have no idea that brokers have fiduciary responsibility to their company and not to the client, which is clearly NOT in the best interest of consumers.

Thank you.


John W. Fiege