Subject: File No. S7-25-99
From: Bryon N Milby, CPA

January 20, 2005

The public and the evolution of the financial services market has moved in the direction of greater investor protection and fiduciary responsibility, perhaps without your help.
Allowing this proposal to proceed is providing regulatory cover for brokers to not really have to match the real demands of the marketplace.
This proposal to allow brokers to act as if they have evolved and mimic the fiduciary role while quite likely retaining their old ways of self interest first, is a true disservice to your role as public protector.

I urge you not to impede the progress of the market, by assisting the established players rather than the public.