Subject: File No. S7-25-99
From: David M KOVER, CFP
Affiliation: Financial Planning Association

January 14, 2005

Giving stock brokers the right to use the same type of fee based accounts that Registered Investment Advisors use only continues to confse the investing public. In a time of increased regulatory oversight, why are we moving backwards? We should be moving forward for more disclosure. We have seen over the last few years what problems occur when disclosure is obscured. Wirehouses advertise on television about how much financial advice and planning they offer only to turn around and claim to the SEC that the advice is only incidental to their activities. The SEC is catering to wirehouses who are speaking out of both sides of their mouth. The SEC should be protecting investors not adding to their confusion. The SEC should completely withdraw this rule not revise it. Thank you.