Subject: File No. S7-25-99
From: Scott Grittinger, CFP
Affiliation: Principal, McCarthy Grittinger Financial Group LLC

September 8, 2004

I request that the SEC withdraw its rule exempting broker-dealers from the Investment Advisors Act of 1940 when offering fee-based brokerage programs.

The bottom line is that advocating a different standard for two investment professionals offering the same service is both confusing to the investing consumer and fails to adequately protect that consumer. Further, it weakens the standard of fiduciary duty owed to the customers of the investing community.

The confusion that this rule has created caters to those in marketing and sales roles whose paychecks are tied more to the success of their broker-dealer, rather than their clients best interests.

It is clear that the public would gain if there was one standard used for all whom call themselves advisors or counselors.


Scott Grittinger, CFP