Subject: File No. S7-25-99
From: Dean L Boebinger
Affiliation: Senior VP, King Investment Advisors

August 23, 2004

WITHDRAW, not amend, the rule proposal. FPA and I believe the rule is harmful to consumers by creating two different standards of conduct for persons offering financial planning services: a higher fiduciary standard for registered investment advisers and a lower one under NASD suitability rules. The rule also exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.