Subject: File No. S7-25-99
From: Thomas A Muldowney
Affiliation: FInancial Advisor

January 31, 2005

Dear SEC...Thank you for your attention to this matter. I am grateful that you have undertaken to revisit this issue. Sadly after having reviewed your response to the original comments and following on the heels of your proposed response, I am left pondering whether or not you fully understand the nature of the problem much less the seriousness of it.

Some people who use the guise of a trusted advisor as a gambit by which they sell products are not people to be trusted. The difficulty, of course, is that you either the SEC or the consumer public cannot determine who is trustworthy and who is not.

Consequently, I ask that you reconsider your proposed response and make both a firm and fair decision...either require folks who call themselves planners or advisors to register with the SEC and follow the required guidelines OR eliminate the requirements for everyone.

The decision to allow the brokerage side of the financial community the opportunity to vet their services without having to follow the registration and operational requirements puts our consumer public, once again, in a disadvantaged position.

The public can often be described as a group f amateur buyers pitted against a group of professional salespeople. Please do not leave the public in such a vulnerable

Thomas A. Muldowney