Subject: File No. S7-25-99
From: John Karoussos

July 22, 2004

As a retired Citigroup MD, having been on the sale side as well as management, my opinion is that there should be a level playing field for IRA and brokers. Weather you are advising someone in the purchase of a single security or the development of an asset allocation model regardless of the complexity or the cost of the advice one should be held accountable under same laws and regulations. You cannot push product for a commission and in a different account offer asset allocation advice for a fee. The system has been abused for ever from both sides of the business. It is time to implement uniform rules. Principal trades, agency trades, allocation of new issues in addition to advisory fees is a public rip off.