Subject: File No. S7-25-99
From: Michael O Babin
Affiliation: Wealth Advisor

January 17, 2005

Since there is another proposal for B/Ds to be able to do Incidental financial Planning without registering as a RIA, there should be very detail rules as to what is and is not incidental. Any type of financial advise is not incidental. The only advise a B/D can give is which fund or management services can be used by an investor and what charges are associated with each fund or wrap program. Any other advise is not incidental.
If you are going to be total objective on this issue, there is no other way.
When a B/D gives advise, the Registered Rep giving the advise has to be an RIA.