Subject: File No. S7-25-99
From: Douglas L Frieson, CFPr
Affiliation: Member NAPFA and FPA

August 23, 2004

I request that you withdraw the rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs. I believe the rule harms 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. Specifically, I object to the rule exempting brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.