Subject: File No. S7-25-99
From: Charles OConnor
Affiliation: Owner, Charles Edward OConnor, Registered Investment Advisor

September 14, 2004

I am a citizen of the United States. Nineteen years ago I earned my CFP designation and currently have a fee-only financial planning practice. I was a registered representative with an independent broker firm for 17 years that I terminated on June 30, 2003.

I strongly oppose allowing brokers who give investment advice as a material part of their relationship with clients to be excused from compliance with the requirements that all other investment advisors must meet.

Today, brokerage firms advertise that they provide a breadth of investment advice to help clients meet their life goals. Their pictures and words in large type show and say this. They suggest that they do nearly anything and everything across the range of financial planning, investment advice, and investment portfolio oversight and/or management.

I can see that these brokers are trying to provide essentially the same services that I provide as a financial planner and RIA, why should it be mandated that they do not need to meet the minimum requirements that the SEC says a real investment advisor is required to meet?

To excuse any investment advisor from meeting the minimum requirements of a RIA, just because of where he or she may work, is inexcusable. Not only would this be unfair to the client, no client would understand this to be possible, especially in the era of expected greater fairness and honesty.

Thank You,

Charles E. OConnor, CFP, EA