Subject: File No. S7-25-99
From: ROBERT J SULLIVAN, CFP
Affiliation: CEO, SULLIVAN SERWITZ INVESTMENT ADVISORS, INC.

August 23, 2004

RE: S7-25-99

Dear SEC Administration,

This letter is to comment on the above referenced file number. Please register my comments as strongly opposed to this rule and a formal request that it repealed.

This approach to regulation of advisors is ill-advised and we support a more carefully considered, comprehensive method to dealing with regulation of advisors. Please consider the input of the FPA and many consumer groups in developing a more uniform solution.

Thank You,

Robert J. Sullivan CFP