Subject: File No. S7-25-99
From: James G. McGrath, CPA, CFP(R), CLU

September 22, 2004

I am a Fee Only Financial Planner and as such have a self avowed Fiduciary responsiblity to my clients. Wire House Brokers, while calling themselves "Advisors", have no such restraint under your current rules or your proposed rules. Please withdraw the proposal, do not amend it.

Make it a level playing field for Advisors and a little easier for consumers to know what they are getting.

James G. McGrath, CPA, CFP(R), CLU