Subject: File No. S7-25-99
From: R. Gay Northrup, CFP, MBA
Affiliation: Financial Advisor, American Express Financial Advisors Inc.

August 23, 2004

The SEC Broker-Dealer Rule Exemption 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. R. Gay Northrup, CFP