Subject: File No. S7-25-99
From: Gerald R. Gortner
Affiliation: Financial Advisor

August 23, 2004

RE: Broker-Dealer Rule Exemption

In these days of your investigations and the Attorney General of New York, this rule is a step backwards in full disclosure. This rule of exemption should be withdrawn.

Gerald R. Gortner, CLU, ChFC, CFPR
Financial Advisor
American Express Financial Advisors Inc