Subject: File No. S7-25-99
From: JoAnn C Todd
Affiliation: Brighton Financial Planning, Brighton Securities

September 8, 2004

I strongly believe the SEC should withdraw its rule exempting broker-dealers from the Investment Advisors Act of 1940 when offering fee-based brokerage programs. They should be held to the same standards as the financial planning profession when assuming the roles they claim in their advertising.

Thank you for your consideration in this matter.