Subject: File No. S7-25-99
From: James Helba, Jr.

January 16, 2005

Clarity of meaning is essential for the consumer to be well served and for the professional to proceed with confidence. Incidental financial planning services is so difficult to define as to be even more difficult to oversee.

I stongly urge that those who are providing any financial planning services be obliged to register appropriately. Such a policy may well be a slight burden to those whose services are arguably incidental, but the full disclosure required under such policy can only help the consumer.