July 27, 2004
Dear Sir or Madam,
Regarding File No. S7-25-99, "Certain Broker-Dealers Deemed Not to Be Investment Advisors," the proposal as it now stands should be withdrawn. Any broker-dealer who is pretending to be a "financial planner" or "financial consultant" under a fee-based system, should be required to disclose ANY fiduciary interest in their advice. The proposed "solely incidental" advice exception is a loophole big enough to drive a truck through. Brokers should not be allowed to act as financial planners and operate under broker rules. Otherwise, these two roles are confused and corrupted (which, of course, may be the intent of some brokers). Thank you.