Subject: File No. S7-25-99
From: Joshua Massey
Affiliation: Investment Advisor

August 24, 2004

I recommend that the SEC withdraw Release Nos. 34-42099
IA-1845, File No. S7-25-99

I believe the rule is harmful to consumers by creating two different standards of conduct for persons offering financial planning services: a higher fiduciary standard for registered investment advisers and a lower one under NASD suitability rules. The rule also exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.