Subject: File No. S7-25-99
From: Paul J Bednarski, CFP
Affiliation: Independent Registered Investment Advisor CA

August 23, 2004

Please WITHDRAW, not amend, the proposed rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs.

I believe the proposed rule is harmful to consumers by creating two different standards of conduct for persons offering financial planning services: a higher fiduciary standard for registered investment advisers and a lower one under NASD suitability rules. In my opinion, the proposed rule also exempts brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.