Subject: File No. S7-25-99
From: Peter A Godino
Affiliation: FPA, CFP

August 23, 2004

I am writing in opposition to the SEC Broker-Dealer Rule Exemption. I believe that the rule proposal should be withdrawn. As a former registered representative RR at American Express Financial Advisors AEFA, I have seen the business model for the fee-based brokerage program. I believe that RRs should be subject to the same requirements as registered investment advisors RIAs, regarding fee-based brokerage programs. Also, I believe that the clients end up paying higher than average fees for this type of program at BDs. The RRs are generally working with clients with fewer investable assets versus RIAs, shouldnt these clients be protected? My opinion is that the rule should be withdrawn.