Subject: File No. S7-25-99
From: Lance Palmer, Ph.D., CPA Utah
Affiliation: Assistant Professor of Housing and Consumer Economics, University of Georgia

August 24, 2004

Gentlemen of the SEC,

I encourage you to withdraw the proposed rule change exempting Broker-Dealers from the 1940 Investment Advisors Act. My concerns are primarily that a two tier system of standards and public accountability will be established, which will encourage a general gravitation toward the lower standard, and as I understand the proposed rule change, Brokers may not be required to disclose conflicts of interests to financial planning clients. A two tier system would confuse and erode consumer confidence at a time when consumers have been shouldered with greater responsibility for securing their own financial futures. While markets should be efficient, they should also be transparent and consistent for consumers. One standard for all individuals and organizations offering financial planning services should be maintained, and it should be the highest standard. Second, undisclosed conflicts of interest lead to abusive business practices, inefficient markets, and financially less well-off consumers. The strongest and most efficient markets, including the financial planning markets, are those in which all information flows freely and is known by both parties. Not explicitly requiring brokers to disclose conflicts of interest is a serious step backwards in regulating the financial planning profession. Again, I encourage you to withdraw the proposed change. Thank you for seeking the publics interest in this matter and thank you for the fine work that you do.


Lance Palmer, Ph.D., CPA Utah