Subject: File No. S7-25-99
From: Michael Pace
Affiliation: Certified Financial Planner

August 23, 2004

I urge the Securities and Exchange Commission to withdraw the proposed rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs.

The proposed rule makes no sense. Broker-Dealers would be allowed to not be accountable under the IA Act of 1940, when they indeed should be. Exempting them would create a huge loophole in the law, and be a major major disservice to the public.

If the reason behind the proposed rule is the manpower needed to enforce the law among Broker-Dealers, I suggest that they be charged fees that would pay for the oversight.