Subject: File No. S7-25-99
From: Alvin J. Rowe Jr.

July 25, 2004


I am a retired investor whose only source of income, aside from Social Security, is my savings. Thus I frequently need advice on trading my investments. I wish to support the lawsuit filed by the Financial Planning Association challenging the proposed rule purportedly clarifying the exception that broker-dealers have from the definition of investment advisors.

Bear in mind that the average investor has little or no concept of the difference between the a broker-dealer and an investment advisor. Thus your proposed rule would basically give the broker-dealer free reign promote the investment by any client in the securities of any company his brokerage represents regardless of its benefit to the client. After all the recent financial scandals that been brought to light I cannot conceive of any justification to allow broker-dealers to take advantage of today's ill informed investors.

To simply state that the investor should do his research before investing is simply ducking the issue. This is not the mid 1900s when basically only the wealthy invested in the market. Now every Tom-Dick-and-Harry has his 401k, IRA or other savings investment. We know little or nothing about financial research and a great many of us have relied on our brokers for investment advice. And it has cost us dearly for the last three years. Thus I sincerely request that you hold the broker-dealers to the same standards which apply to independent financial advisors.

Alvin J. Rowe Jr.

Suwanee, Ga.