Subject: File No. S7-25-99
From: Michael A Calabrese

September 8, 2004

The SEC should withdraw its rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs.

The investing consumer is not provided sufficient protection by differing standards for two distinct groups offering the same service.

Further, the standard of fiduciary duty owed to the customers of the investing community is weakened by such discrepant standards.

Please reconsider your stance.