Subject: File No. S7-25-99
From: Raj P Pillai, Ph.D., CFP
Affiliation: Program Director, CFP-Board Registered Program, Cuyahoga Community College

September 7, 2004

After all that has transpired in the financial services industry in recent years, it is time to raise the bar, not lower it.

I urge the SEC to withdraw this proposal which is harmful to consumers, as it creates two different standards for those offering financial planning services: a higher fiduciary standard for registered investment advisers and a lower one for broker dealers under NASD suitability rules.

The SEC needs to protect the consumer by holding broker-dealers accountable to the same standards as Registered Invesment Advisors when offering fee-based financial planning. The SEC should withdraw this proposed rule.