Subject: File No. S7-25-99
From: Kelly F Crane, CFP, CFA, CLU
Affiliation: Napa Valley Wealth Management

January 14, 2005

Please apply a rigid definition of financial planning and advisory services to the B/D rule. The playing field of all advisors should be level and not based upon an arbitrary standard or some false measure such as method of compensation or B/D/Bank affiliation. All advisors/registered reps. should be held to the highest standards when providing comparable services to their clients. The public does not see a distinction between the groups when they claim to offer the same services, yet are subject to different rules/standards. Parity will help protect the public