Subject: File No. S7-25-99
From: Michael Boyd, CFP
Affiliation: Financial Planners Asso.

January 11, 2005

I do not believe that it is reasonable for a Brokerage to say that the financial advice they are giving is incidental when they are advertising and telling the general public that they are offering financial planning, financial reviews or other such services. Especially when they are charging a fee for this and generating reports that are projections of what the client can expect from thier financial situation. This IS investment advising and really is what the Investment Advisors Act of 1940 was trying to address.

After all the problems we have had with investor confidence, everything possible should be done so that investors can feel they are being treated fairly. Allowing Brokerages to skate around the rules is not going to do this.