Subject: File No. S7-25-99
From: John Beeson

August 23, 2004

To Whom it May Concern:

Regarding Certain Broker-Dealers Deemed Not To Be Investment Advisors, I believe the public would be better served by requiring broker-dealers offering fee-based programs to comply with current registration requirements of the Advisors Act which would level the playing field for disclosure of conflicts and fiduciary conduct by anyone meeting the definition of investment advisor.

I started my financial career working for Merrill Lynch in 1975 and later worked for Dean Witter in the 80s. I know first hand how brokers loose track of what is best for their clients and instead are focused on what makes money for them and their firm. Until broker dealers change the compensation system, the SEC needs to keep a tight leash on broker dealers because of the general conflict of interest they have with clients.

John Beeson, CFP, MBA
Registered Investment Advisor