Subject: File No. S7-25-99
From: Gary D DeVicci
Affiliation: RIA BD Owner

August 24, 2004

This rule hurts consumers by comingling the duties of an adviser and a product sales person. The 40s Act separated these functions for the benefit of the public. An adviser should represent the clients interests without concern for the products used.
Clearly, salespeople have product placement responsibilities which make them agents of the BD. This should not be shared with the responsibility of being an objective advocate of the client.
Please eliminate this rule.