Subject: File No. S7-25-99
From: Carl J Kunhardt
Affiliation: Investment Advisor

August 24, 2004

Re: Release Nos. 34-42099 IA-1845 File No. S7-25-99

I strongly urge you to withdraw, not amend, this fundamentally flawed proposal. It is incomprehensible that in the current climate of focus on investor protection, the commission can even possibly contemplate a proposal that exepmts sales professionals from full disclosure. This is not in the best interest of the investing public and will further erode the confidence the average investor has in the regulation of this industry.

It is telling that in addition to the Financial PLanning Association, the Consumer Federation of America and AARP also strongly object to the rule.

Some things are so flawed they cant be fixed. This proposed rule is such an instance and demands to be withdrawn, not amended.

Thank you ...
Carl Kunhardt