Subject: File No. S7-25-99
From: Kristi J Heffron
Affiliation: Chief Compliance Officer, Green Investment Management, GIM

August 24, 2004

We urge you to withdraw this rule. Green Investment Management believes the rule to be harmful to consumers by creating two different standards of conduct for persons offering financial planning services: a higher fiduciary standard for registered investment advisers and a lower one under NASD suitability rules. In addition, it provides an unfair burden of compliance on small investment advisory firms while allowing larger firms to ignore important compliance procedures.