Subject: File No. S7-25-99
From: Michael Pace
Affiliation: Michael Pace, CFP

January 14, 2005

I have been following the progress of the proposed SEC regulations for incidental financial planning advice given by brokerages.

I believe that financial advice should only be given by those who are qualified to do so. If employees of brokerages believe they are competent to give such advice or if the brokerages themselves believe their employees have the required competence, then these employees should come under the same regulations as financial planners/investment advisers.

All financial planning advice is important. Oftentimes, crucial life decisions are made by the public based on advice given, including that given by employees of brokerage firms. Anyone giving such advice, upon which the public relies, should be held to the full level of responsibility and disclosure of the U.S. securities laws.

To have more than one set of laws for people offering financial advice is a monumental disservice to the public. The public has the right to be protected from and well informed about those individuals providing advice.

No financial planning advice can be incidental. All who give financial advice must be held to the same standards.