Subject: File No. S7-25-99
From: Ann Harrod, CFP
Affiliation: Harrod Financial Planning

January 14, 2005

I think the SEC would be professionally unfair to allow Series 7 registered representatives to offer broad, fee-for-service financial planning advice to clients without first qualifying and registering as Registered Investment Advisor representatives, just as the remainder of us are required to do. And, from the consumers point of view these Series 7 people really do not have the broad background and academic understanding entailed in advising for these objectives, even though the employer assumes responsibility as Registered Investment Advisor. Fee-based advising is a lot more detailed than understanding a clients tax situation, risk tolerance and so on relative to choice of investments.