Subject: File No. S7-25-99
From: Allan W Moskowitz, CFP
Affiliation: Principal, Progressive Wealth Management

January 17, 2005

To whom it may concern:

Please consider that when a registered representative of an NASD broker/dealer firm does financial planning, it may be done in order to sell the client a product, though it may fill a client need. However, financial planning is not incidental to brokerage. Therefore the ruling should be removed entirely. Financial planning is done to help clients clarify and understand their financial situations, needs, goals, etc and to then lastly to match these needs with appropriate products, not the other way around as is typically done incidentally to the brokerage side of the business. I hope you can see the difference, as the brokerage business is laden with conflicts of interest that are infrequently disclosed to unsuspecting clients in sales-based relationships. Thank you for your time.