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

January 16, 2005

We have provided financial planning services to the public since 1978. We initially registered with the SEC in 1981 and after the new regulations in the late 1990s shifted our registration to the state. Obviously We have a long history of both service and compliance. We maintain dual securities licences and RIA reguirements. As an independent, We have experienced first hand the increasing regulation, paperwork and cost that is ulitmately passed on to both our business and our clientele. Many of our clients have been through this 25 year period and our amazed at the increased amount of paperwork. We make jest of the procedures to encourage client cooperation by saying obviously the compliant follow the rules and the rogues ignore the rules.The rules can be onerous and should be simplified. In maintaining this dual registration We find it inconceivable that theythe brokerage firms and the banks should be exempt from these regulations. Secondly in being loosely affiliated with a major clearing firm which is both, they have grabbed the title financial advisor while relegating the broker title to the trash heap. Their personnel do not provide the service,do not have the training yet the public can not make the distinction between a broker nay financial advisor and a real advisory firm providing investment advise.