Subject: File No. S7-25-99
From: Donald E Whalen
Affiliation: National Association of Personal Financial Advisors

August 24, 2004

The rule that has two sets of standards -- one for broker-dealers and another for RIAs -- should be withdrawn. The SECs job is to protect the consumer, something I believe it does a good job of. This rule, however, does not protect consumers, but leaves them at the mercy of individuals who are offering advice, yet are not being held to a high standard of fiduciary accountability.

At a time when investors are already very skeptical after having witnessed recent mutual fund scandals and corporate governance issues, they want to be sure that the SEC is doing everything it can to protect them from people who would wreak havoc with their investments. By not holding broker-dealers to a higher standard, there are bound to be some issues down the road that will lead people to have less confidence in the market, and inevitably less confidence in the SEC.