Subject: File No. S7-25-99
From: David E Feagans
Affiliation: Retired Mechanical Engineer

August 26, 2004

I urge you to WITHDRAW, not amend, the proposed rule for two reasons:

The proposed rule allows 2 standards of conduct. One for Registered Investment Advisors and a different, less stringent one, for Stockbrokers and their firms

The proposed rule is anti consumer. By permitting non disclosure of conflicts of interest, it allows stockbrokers and their firms to misrepresent their primary sales role as one of a fiduciary advisor by receiving a fee for advice.