Subject: File No. S7-25-99
From: Kevin Blood
Affiliation: FPA,

August 23, 2004

Please withdraw the rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs. These rules should be on an equal standing for the advice given, without regard for the broker dealer affiliation or not. I have always associated with a broker dealer and those in my industry should have the same rules for the same management process. Making an exemption here does not seem to make sense.

Thank you for re-opening the discussion on this.


Kevin Blood