Subject: File No. S7-25-99
From: Paul W Whaley
Affiliation: General Securities Principal/Raymond James and Associates/Financial Planning Association member

August 23, 2004

The proposed rule should be withdrawn from consideration. An amendment of the broker dealer rule exemption would be flawed because of the inherent conflict between broker compensation and recommendations, since there is no fiduciary requirement of the broker.

In addition, the AARP and the Consumer Federation of America both strongly object to the rule.