Subject: File No. S7-25-99
From: Jeff B Witten, CFP

September 28, 2004

Here is an opportunity for you to eliminate a loophole and restore the integrity of the Investment Advisers Act.

The proposed rule that expands the EXEMPTION for broker-dealers from fiduciary and disclosure standards of the Investment Advisers Act of 1940 is WRONG. Brokerage firms now call their salesmen Advisers, what does that title imply to you, what does it imply to the public?

A loophole in the present Act allows broker-dealers to operate as ADVISERS with virtually NO disclosure of conflicts. The proposed rule EXEMPTING fee-based brokerage programs from the fiduciary and disclosure standards of the Advisers Act, requiring only minimal disclosure that the account was a brokerage account is WRONG.

Financial Planning is not INCIDENTAL to achieving ones life goals and dreams.

Thanks, Jeff B. Witten, CFP
Certified Financial Planner