Subject: File No. S7-25-99
From: KENNETH R RUHRUP, CFP, ED.D.
Affiliation: FINANCIAL PLANNING ASSOCIATION FPA

August 23, 2004

I CONCUR WITH FPAS POSITION TO WITHDRAW RULE S7-25-99. THIS RULE WILL CONFUSE THE INVESTING PUBLIC BY CREATING DIFFERENT STANDARDS OF CONDUCT FOR PERSONS OFFERING FINANCIAL PLANNING SERVICES: A HIGHER STANDARD FOR REGISTERED INVESTMENT ADVISERS AND A LOWER ONE UNDER NASD SUITABILITY RULES. BROKERS SHOULD NOT BE EXEMPT FROM DISCLOSING CONFLICTS OF INTEREST IN CONNECTION WITH THE OFFER OF FINANCIAL PLANNING SERVICES. I HAVE BEEN PRACTICING FINANCIAL PLANNING FOR 20 YEARS AS A NON-BROKER AND HAVE ALWAYS OFFERED FULL DISCLOSURE AND CONFLICTS OF INTEREST. ANYONE AND EVERYONE PRACTICING FINANCIAL PLANNING SHOULD BE REQUIRED TO DO THE SAME TO LEVEL THE PLAYING FIELD AND NOT OFFER OPPORTUNITY FOR HIDDEN AGENDAS OR DISGUISED AGENDAS WHEN OFFERING PUBLIC FINANCIAL SERVICES.