Subject: File No. S7-25-99
From: Kenneth L. Kesler, RegRep
Affiliation: SWS Financial Services

February 8, 2005

My input into this flap is that you must keep it as simple as possible. And to me the simplest demarcation is simply whether you have discretion or not. If you have discretion then you are an RIA and must maintain a fee only conmpensation structure. If you do not have discretion then you may charge a fee or a commission, but not in the same account.

Ken Kesler