Subject: File No. S7-25-99
From: Ulrich E Keller, Jr.
Affiliation: AIMR,FPA

September 22, 2004

I am very much against any proposed rule for investment advisors which would exclude any brokers or broker dealers. Brokers are not trained as money managers. Many lack financial degrees or backgrounds necessary to call themselves investment advisors.

We see several egregious cases a year of clients going to brokers receiving poor advice, unfortunately usually after they have lost substantial amounts of money or locked in to high commissioned investment products that are inappropriate for risk tolerance or tax considerations.

SEC audits are necessary to require brokers to act as a fiduciary in the best interest of clients needs and not their own.


Ulrich E. Keller, Jr.