Subject: File No. S7-25-99
From: James A Holm

August 25, 2004

I would like to urge the Commission to withdraw, not amend, the proposed rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs. I concur with the FPA that the rule is anti-competitive by creating two standards of conduct for persons offering financial planning services: one for registered investment advisers and one under NASD suitability rules and anti-consumer, by permitting non-disclosure of conflicts of interest by registered representatives.

I understand that the Consumer Federation of America and AARP also strongly object to the rule.