Subject: File No. S7-25-99
From: Eric J. Seff
Affiliation: Certified Financial Planner TM

August 23, 2004

I urge The Securities and Exchange Commission to withdraw its rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs.

As a fee-only financial planner, I support identical standards of conduct for all persons offering financial planning services.