Subject: File No. S7-25-99
From: Janet Tyler Johnson
Affiliation: Clifton Gunderson Financial Services

August 25, 2004

I strongly urge the SEC to withdraw the rule that would exempt registered representatives from The Investment Advisors Act of 1940 when giving investment advice as brokers. To protect the public, both advisors and registered reps, when giving investment advice, must be held to the same standards. I currently am licensed to act as a registered investment advisor representative as well as a registered representative and feel that no matter which license Im acting under, the client deserves full disclosure of how I am paid, any conflicts of interest, and that I will put their interests first. As an investment advisor representative I am held to the standard of a Fiduciary when giving investment advice. When acting as a broker and giving investment advice, its still investment advice. Does the client deserve less because Im giving advice under one hat vs. another? In the interests of the public, I respectfully request that you withdraw this rule.