Subject: File No. S7-25-99
From: Timothy J Holsworth, CFP, CLU, ChFC
Affiliation: Vice President Laco Financial Services

January 17, 2005

I urge the SEC to completely withdraw the rule expanding the disclosure requirements for brokerage firms using fee-based programs and to expand on what is solely incidental brokerage advice not subject to the Investment Advisors act of 1940.

Fee-based investing does away with the traditional conflict of interest inherant witin commission trades. Its popuularity and growth is a testament by consumers they are tired of the pressure and bias that commission trading brings. I cannot understand your concern regarding fee-based accounts, and find your overall attitude against them appalling.

Its time you focused on the bad apples in this business and stop messing with fee-based accounts in general and non-commission oriented trading in particular.