Subject: File No. S7-25-99
From: James L Gruning, MBA, RFC
Affiliation: FPA

January 17, 2005

I think that if one takes a fee for their advice they should be held to fiduciary standards. Thus any advisory fee that is not commissioned based would qualify.

Please dont let the big B/Ds push through rules that absolves them of their fiduciary duties to their clients when they take fees in ieu of commissions.