Subject: File No. S7-25-99
From: Milo M Benningfield, J.D.

August 25, 2004

Dear Sir or Madam,

I am writing to offer my support for WITHDRAWAL of the rule proposing broker/dealers be exempt from registering as investor advisors when providing fee-based advice.

I believe withdrawal of the rule would be a good step towards injecting more accountability into the current financial-advice system in the U.S. Of course, withdrawal of the rule might actually serve to create more competition for fee-only Registered Investment Advisors such as myself from fellow fiduciaries at the brokerage firms. But I would rather see such competition than allow individual investors to continue to be subject to the investment abuses committed by sales reps masquerading as trusted advisors that I see in my practice.

I also believe withdrawal of the rule would do much to restore the credibility of the SEC in the financial-planning profession as a truly independent body dedicated to protecting the interests of the investing public.

Thank you for your attention to this matter.