Subject: File No. S7-25-99
From: Cornelius H Van Zutphen, Jr
Affiliation: CERTIFIED FINANCIAL PLANNER practitioner, Independent RIA

September 7, 2004

I believe that the SEC should withdraw its rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs.

Having a different standard or policy for two distinct groups offering the same service does not offer the investing consumer adequate protection. Further, it weakens the standard of fiduciary duty owed to the customers of the investing community.

Please reconsider the stance that you have taken.


Cornelius H. Van Zutphen, Jr., CFPR
Independent Registered Investment Advisor