Subject: File No. S7-25-99
From: Mike Paccioretti

August 27, 2004

NO, NO, No, I strongly urge you to withdraw your proposal to exempt broker/dealers or other financial organizations from the requirements set forth in the Securities Act of 1940 when they offer fee-based brokerage programs. It is not in the best interest of the public to be offering financial advice without the advisor being subject to regulatory oversight. Again please withdraw your proposal.

Mike Paccioretti