Subject: File No. S7-25-99
From: Joseph D Helms, CFPtm

August 24, 2004

I would resepctfully ask that you withdraw the proposed rules that would create two sets of standards under which financial professionals are required to operate by exempting broker-dealers from the Investment Advisers Act of 1940. Having worked for a broker-dealer for several year before moving to a fee-only practice I have first hand knowledge of the pressure an advior faces when making investment product recommendations. As a practioner I feel I have an obligation to the public to fully disclose any potential conflicts of interest, whether it is so only in apprearance or acutally exists. Withholding information from the client regarding potential conflicts of interest, could lead the client to believe the adviosr is acting soley in the clients interest when in fact there may be another motivation behind the recommendations made by the advisor.

Thank you for your consideration of this matter.