Subject: File No. S7-25-99
From: Richard K OKeefe
Affiliation: Chief Investment Officer, First Affirmative Financial Network

September 8, 2004

Stockbrokers POSITION themselves as trusted advisors, working in the interest of their clients. Therefore, they should be required to fulfill the same obligations as advisors who actually do represent their clients interests first. Do NOT exempt brokers from satisfying fiduciary requirements.