Subject: File No. S7-25-99
From: Roxanne Fleszar
Affiliation: CFP, ChFC

September 17, 2004

As a financial planning professional for the past 25 years I am well aware of the complexities in the securities industry. The consumer is rarely well versed in types of services and the costs incurred for our services. As a Certified Financial Planner, registered with the SEC as an investment advisor, I am held as a fiduciary to my clients. I provide full disclosure to my clients regarding how I administer my business, whom we are affiliated with and how we receive our compensation.

Many of the recent so called scandals in the securities industry have been common practice since I have been involved in the industry. I have had numerous clients over the years come to me after their accounts have been churned at brokerage houses and where they have acquired what I would consider to be inferior performing mutual funds or variable annuities with high expenses and sales charges. Often the products they have acquired are not suitable for their age, financial status nor risk tolerance.

The proposed rule entitled Certain Broker-Dealers Deemed not to be Investment Advisors causes additional confusion to consumers and does not hold a registered representative to the same standard of prudence, diligence nor rules of disclosure. Especially in light of recent news, the public deserves more from the SEC.

I have read the June 21, 2004 letter to Mr. Jonathan Katz of the SEC from Duanne Thompson of the FPA and wholeheaartedly endorse the positions he has stated. I steongly encourage the SEC to withdraw or significantly amend the above-referenced rule.


Roxanne E. Fleszar, CFP, ChFC
Financial Resources Management Corporation