Subject: File No. S7-25-99
From: Fred J. Stewart, Ph.D., CFP
Affiliation: President, F. Stewart Associates, P.C.

August 23, 2004

I have been registered as an Investment Adviser for over 15 years. I have always been an independent fee-only adviser and I strongly support the requirement of a fiduciary standard for registered investment advisers. I believe that it not in the publics best interest to have a lower standard of conduct available for some advisers, depending on whether or not the adviser is also a broker. I want to ask you in the stongest terms I can to withdraw this rule proposal and not merely make revisions in the rule. The public interest demands the highest possible ethical standards of conduct for those individuals offering financial advice. Please withdraw this rule proposal.