Subject: File No. S7-25-99
From: Jeffrey N. Coffee

February 15, 2005

Dear Sir:

I do not think itís in the best interest of investors that broker / dealers would be allowed to avoid the fiduciary and disclosure standards of the Investment Advisers Act of 1940 while acting as investment advisers and offering financial planning services.

What I fail to understand is why the SEC would propose a rule that allows brokerage firms to misrepresent and actively market themselves to investors as trusted advisers - instead of disclosing their true role as sales representatives.

What is going to happen is you will have stockbrokers disguising themselves as financial planners, financial consultants, investment advisers, etc. when in reality they are just a financial sales person, falling under the more lenient broker / dealer sales regulations. Investors will once again be mislead by their stockbroker and again wonder what the SEC was doing to protect them.

Frankly, given all the scandals in the investment brokerage industry, Iím extremely disappointed that the SEC is not aggressively pushing to have anyone who incidentally or not gives advice about securities covered by the Investment Advisers Act of 1940.


Jeffrey N. Coffee