Subject: File No. S7-25-99
From: Jeff Armstrong
Affiliation: Financial Advisor, American Express

January 17, 2005

1. How should the SEC draw the line between financial planning services that are incidental to brokerage and those that are not? Can such a line be drawn?
2. Do you think the SECs approach, to interpret financial planning as not solely incidental to brokerage services, is workable? Do you think there are other marketing terms that a broker could use to provide similar services and thereby evade restrictions on use of the term financial planning?
3. Should the SEC also or alternatively attempt to identify specific types of financial planning services that would or would not be incidental to the brokerage business?
Consumer questions