Subject: File No. S7-25-99
From: John R Goodrich

September 2, 2004

I wisht to express my position on the exemption Broker-dealers have of the Investment Advisors Act of 1940. Personally I urge you to withdraw the rule, the broker-dealers have a loophole which needs to be rectified. I have been associated with a broker dealer for almost 20 years and feel the additional scrutiny is appropriate.

thank you for your consideration