Subject: File No. S7-25-99
From: Edward D. Fulbright, CPA, PFS

September 21, 2004

Giving Broker-Dealers exemptions from being consider an investment advisor will lead to the consumer being greatly abused. The rule needs to be withdrawn, not modified because it creates irrepairable harm to the consumer. The consumer will not be able to differiated from the investment broker and the financial advisor giving objective advice.