Subject: File No. S7-25-99
From: Ralph Ujano, Jr.
Affiliation: Certified Financial Planner, Certified Public Accountant

August 23, 2004

Given all of the scandals among the brokerage houses, insurance companies, etc., it is apparent that these firms need to be held to a higher standard in how they interact with their clients, not a lesser one.

The SEC has fined many of these firms due to their conflicts of interest, after market trading, soft dollar arrangements, and self dealing, yet you are still considering the passage of this broker dealer exemption. What good do fines and penalties do without a longer term standard in place to eliminate these conflicts of interest?

It is vital to the safety of investors worldwide that this proposed exemption be withdrawn and a new standard with GREATER accountability and stewardship be put in place.

Thank you.

Ralph Ujano, Jr., CPA, CFP, MS