Subject: File No. S7-25-99
From: Robert A Gordon
Affiliation: Member, Financial Planning Association

August 26, 2004

To WHom It May Concern:

I am writing to urge you to WITHDRAW, not amend, the proposed rule changes to the Investment Advisors Act of 1940, proposed under file number S7-25-99. I believes the 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. The rule also exempts, in effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services. I cannot imagine how these propsed rule changes would do anything but harm the investing public

As you already know, both the Consumer Federation of America and AARP also strongly object to the rule.
Thank You for your time,


Bob Gordon, President
Robert Gordon Associates, Inc
A Registered Investment Advisor