Subject: File No. S7-25-99
From: Helen L Modly, CFP
Affiliation: Focus Financial Consultants

September 1, 2004

I urge the SEC to withdraw the proposed amendment in order to increase the publics ability to distinguish between financial advisors acting in a fiduciary capacity, and financial product salespeople who work for their employers. I previously worked for a NASD broker-dealer and it was quite clear that we were agents of the BD, not agents for the client.

When the public pays for financial advice, that advice should not be a sales proprosal in disguise. If the broker-dealers want to deliver the same financial planning services in a fiduciary capacity, then the registration process should be consistent with the process that RIAs currently are subject to.