Subject: File No. S7-25-99
From: Duffy G Elliott, Sr, CPA
Affiliation: FPA, Georgia Society of CPAs

February 4, 2005

As a former employee of a large wirehouse I am 100 sure that these are the Advisors that do need to be covered by the rule.

Most of the training they give their employees is sales training. The is no investment analysis training or financial issues training. It is all about sales and revenues.

What the people need is good advice from people educated in the areas of financial services, financial planning etc. It is not in the best interest of the public to have people selling an investment without a clear understanding of how that investment may or may not be appropriate for the client.

Key issues the advisor should know before determining the appropriateness of an investment for a specific client include the clients goals, risk tolerance, other resources and allocation of other investments. This is just a start if the advisor is going to do the job right.

Banks and wirehouse employees need as much if not more oversight and regulation as any in the industry due to their lack of training on the right issues.

Thank you for looking out for the investor, not the big money Financial Services Companies.

Duffy G. Elliott, CPA