Subject: File No. S7-25-99
From: James Heard, CFP
Affiliation: President, Windham Brannon Financial Group

February 1, 2005

We would support the SECs position on non-discretionary accounts at broker-dealers as long as there is little or no financial planning being done for the client. When financial planning is done for a client, the investment relationship is no longer incidental even if it is non-discretionary.