Subject: File No. S7-25-99
From: Cathleen Burns, CFP
Affiliation: Financial Advisor, Morgan Stanley

January 18, 2005

Please withdraw the rule that would deem certain broker/dealers not to be investment advisors. The public cannot determine the difference between brokerage firms and advisory firms, especially when brokerage firms are aggressively marketing their advice as their value. It is not helpful to the client to bury more disclosure language in the paperwork. This only adds to the confusion and mistrust many clients already have for brokerage firms. The way to help clients is to keep it simple and apply the rules uniformly to all who offer investment advice. I would be hard pressed to find clients who think my advice is only incidental to my services. I rather think my value lies in my advice, not in my ability to sell products.