Subject: File No. S7-25-99
From: John Sullivan
Affiliation: FPA

February 3, 2005

current areas of nondisclosure:
-whether or not there is an investment banking relationship involved with the particular investment in question. For example, the investment firm has a high rating on a stock that they are proposing to a customer and neither the customer nor the broker knows that it is in the interests of investment banking that this stock be pushed.

-whether or not a fund or annuity is sticky. For example, a propriety product cannot be moved to another firm without paying costly cdsc or surrender fees. These products keep the assets in place after they are sold without disclosure of this very relevant fact to the customer. Typically, sticky assets also pay the broker more than products that are portable to another firm.

-the brokers qualifications to give investment or financial planning advice. What does the term financial advisor mean? Normally it means stockbroker, a designation that has already been destroyed by the actions of stockbrokers. Now the car thief wants to address the public as transportation specialist. Let those who created the poor reputation of stockbrokers repair the damage by going legit as stockbrokers rather than walk away from the damage and call themselves something else.