Subject: File No. S7-25-99
From: David W. Demming
Affiliation: FPA

August 24, 2004

We think it is a great disservice to the US consumer that you maintain a double standard for independant investment advisors and exempt from regulation personnel from banks and brokerage firms. We embrace our responsibily as fiduciaries while they flee from regulation and hide behind other licences and exemptions. Bluntly you either provide investment advice and accept the responsibilty or shirk from it and hide in the shadows. We have provided independant counsel for over 25 years providing advice to individuals. Brokers and bankers can not have it both ways, calling themselves Financial Advisors yet expecting to be exempt. Our concern is that you are raising the cost of providing independent advise to the average and mass affluent and allowing high cost marginally ethical sales organizations to justify their existance because of the cost of compliance while squeezing lower-cost more consumer-oriented with more onerous compliance procedures. We were not the problem before and certainly not now,require the banks and brokerage firms to comply and stop picking on the independant advisor. David W. DemmingCFP