Subject: File No. S7-25-99
From: Randolph M. Martin, CFPR
Affiliation: Certified Financial PlannerTM

August 23, 2004

I am a registered representative of Jefferson Pilot Securities as well as an OH licensed investment adviser. I see no reason why broker-dealer representatives should not be held to the same fiduciary standards as investment advisers when providing investment management for fee advice. Setting different standards for different professionals is confusing to the public and does nothing to promote their well being. I personally believe the rule should be withdrawn if it doesnt do anything to protect the average investor.

I have witnessed numerous occasions where bank securities representatives have given what I believe is advice contrary to the investors best interest. Advice is advice is advice regardless of the professional providing that advice. Why not have everyone play by the same rules? It doesnt make sense to me as a professional. How can it make sense to the investing public?