Subject: File No. S7-25-99
From: Joseph R Garipoli
Affiliation: RR IAR CFP member AIMR, NYSSA. FPA

August 23, 2004

In my 30+ year career in financial services I am hard pressed to remember a proposal that represents such a quantum leap backward in regulatory progress for accountability, uniformity and public protection. Carving such an exception for broker/dealers to compliance to generally accepted and highly regarded advisory rules of professional responsibility, competence, transparency and public interest smacks of political accomodation. Ironically,it comes at a time when the advisory business has been steadily raising the bar in terms of best practices and continuing ed and the public and regulators have very loudly demanded more uniformity and accountability. Furthemore, in the context of all of the recent high profile mischief in our industry and the glare of public scrutiny on those people and instritutions that regulate our business, I cant imagine a worse environment to be perceived to be inexplicably and unfairly tilting the regulatory and competitive playing field toward one large prominent group of financial providors at public expense and to the compeptive detriment of others .