Subject: File No. S7-25-99
From: Robert K Haley, JD, CFP
Affiliation: President, Advanced Wealth Managment

August 23, 2004

I have worked both at a wire-house, that is, a major brokerage firm, and in the independent channel. It is a sham and a huge dis-service to the public to exempt the broker-dealers from registration of the Investment Advisor Act. Supposedly the exemption is available only if advice is incidental to their brokerage activity. Please look at their advertising. I think they are clearly communicating that they want to be our financial advisor, financial counselor, financial consultant, and that financial planning is core to their marketing and their activities. To turn around and claim for licensing purposes that advice is only incidental to their business is so blantant a fiction it makes one wonder how the rule ever got promolugated in the first place.