Subject: File No. S7-25-99
From: Michael E. Simon

July 22, 2004

Morgan Stanley calls its stockbrokers "Financial Advisors." That term is used on their business cards, on each customer’s account statement and in the company’s correspondence to customers. If MichelleSingletary’s July 22, 2004, article in the Washington Post is correct, the proposed regulation would formalize their exemption from the fiduciary and disclosure standards of the Investment Advisers Act of 1940.

To do so would be poor public policy. In my opinion individuals, including stockbrokers, who hold themselves out to consumers as "Financial Advisors," "Financial Planners," "Financial Consultants," or "Investment Advisers," should be subject to the fiduciary and disclosure standards of the Investment Advisers Act.

Michael E. Simon