Subject: File No. S7-25-99
From: clifford e fowler, jr, cpa/pfs
Affiliation: aicpa, pfs designation committee, chair of KYCPA financial planning section

January 26, 2005

-it appears to me you are opening up a door for abuse and/or confusion. I would be inclined to think anyone who is working with a client in the investment area should be under the sec rules. There are always those who would like to skirt the ethics and rules and opening this type of door is allowing them that opportunity. Anyone who benefits financially directly or indirectly should be under the sec rules. Money is usually the driver that stears people off course