Subject: File No. S7-25-99
From: Michael W. Miller
Affiliation: Principal, PlanFIRST, Inc.

August 26, 2004

I am writing to express my opposition to the SEC Broker-Dealer Rule Exemption and to ask that you withdraw the rule proposal, rather than amend it. It creates two different standards of conduct for persons who offer financial planning services. In addition, it effectually exempts brokers from being required to disclose conflicts of interest with regard to the offer of financial planning services. Consequently, this rule is not in the best interest of the consumer.

I trust that, after further consideration, the SEC will decide to withdraw the Broker-Dealer Rule Exemption.