Subject: File No. S7-25-99
From: Evan H. Farr, J.D.

July 22, 2004

Broker-dealers should not be allowed to avoid the fiduciary and disclosure standards of the Investment Advisers Act of 1940 while acting as investment advisers and offering financial planning services.

Evan H. Farr, J.D.
Certified Estate Advisor, National Association of Financial and Estate Planning*
Member, National Academy of Elder Law Attorneys &
Tel: 703-691-1888 Fax: 703-940-9160
3927 Old Lee Hwy, Suite 101C, Fairfax, VA 22030