Subject: File No. S7-25-99
From: Roy C Whitmore
Affiliation: CFP, CSA

October 4, 2004

I urge you to WITHDRAW your proposal to exempt broker/dealers or any other financial organizations from the requirements set forth in the Securities Act of 1940 when they offer fee-based brokerage programs.

I believe that it is contrary to the publics interests to be offered financial advice without the advisor being subject to regulatory oversight. Furthermore, if a company is PRIMARILY in the business of selling products, it should not be allowed to market itself as an advisor if it isnt willing to be regulated as such.

Thank you, in advance, for doing what is necessary and appropriate to maintain integrity in the financial advising / investing professions, and for keeping in mind, at all times, the concerns and interests of the people being served by these organizations.