Subject: File No. S7-25-99
From: Richard Millar, CFP

August 23, 2004

Sirs,
Please do not mearly ammend the rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs.

THIS RULE SHOULD BE WITHDRAWN, not changed. The RIA rules are adequate and well tested as they are now.

Please withdraw this confusing rule.

Thank you.

Richard Millar