Subject: File No. S7-25-99
From: Al Van Kampen

August 20, 2004

Ladies & Gentlemen:

I strongly oppose adoption of any rule that would exempt broker-dealers from the Investment Advisers Act of 1940 simply because they are broker-dealers. The proposed disclosure that the accounts are "brokerage accounts" will provide no real information to the investing public that the broker-dealer is in fact not the same as the investment adviser providing exactly the same services, but with greater training and duties. Indeed, as noted in the discussion of the proposed rule, most of the broker-dealers also are registered as investment advisers. The proposed rule would permit broker-dealers -- as they do now -- to claim that for certain accounts they did not have the higher duties and obligations of an investment adviser, while they advertise that they are providing the same type of investment advice as an investment adviser. This rule, if adopted, will only legitimize the sham that is currently in operation.

Al Van Kampen
1001 Fourth Avenue, Suite 4050
Seattle, Washington 98154
Tel: 206/441-1121
Fax: 206/405-2825