Subject: File No. S7-25-99
From: Paul C Brown
Affiliation: Associate Planner

January 14, 2005

I am very much in favor of complete withdrawal of this rule, not revision. I believe that the SECs duty is first and formeost to the consumer, not to protect big brokerage firms. If these brokerage firms are going to continue to hold themselves out to the public as financial advisors, they need to register as RIAs, just like the rest of us. Your careful consideration is requested.

Caleb Brown