Subject: File No. s7-25-99
From: Judith H Heltzel, CFP r
Affiliation: Certified Financial Planner licensee

August 23, 2004

I a writing to urge the Securities and Exchange Commission to withdraw the rule proposal that will exempt broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs. I agree with the Financial Planning Associations position that this proposed rule would be harmful to consumers by creating two different standards of conduct for persons offering financial planning services, i.e. a higher standard for those of us who operate as registered investment advisers and a lower one under NASD suitablity rules.

Thank you for your consideration.

Judith H. Heltzel CFP r