Subject: File No. S7-25-99
From: Ross D Pauley, MBA, CFP, CSA, BCI
Affiliation: President, Pauley Financial Services, Inc.

September 7, 2004

If you watch any TV at all especially high dollar sporting events, youre sure to note the brokerage firms touting their financial advice.

If you check the business cards of the brokers in any brokerage firm, you will not be able to find broker anywhere on any of them - they all now read Financial Advisor, Financial Planner, Client Relationship Manager, Financial Consultant, or some permutation thereof.

It certainly appears that they are offering financial advice, so why should they be exempt from registration?

To paraphrase a former Secretary of the Treasury, If it walks like a duck, quacks like a duck, and swims like a duck, its a duck.

So... If they advertise financial advice, say theyre financial advisors on their business cards, and offer finanial advice, then theyre financial advisors so... regulate them the same way the rest of us ducks are regulated

Withdraw the rule proposal and do not amend it.