Subject: File No. S7-25-99
From: Roger R Bell, II

January 19, 2005

My first exposure to the securities industry was in 1974 as a retail and commercial banker where I assisted on estate and trust accounts. I subsequently became directly involved in the securities and investment planning industry after obtaining my Series 66 and Series 7 license to include Life/Health,PC licenses, and becoming a IAR.

Over the past 30 yrs, I have always understood the difference between a Stock/Mutual Fund Broker and an
Investment Advisor, and a person or business that also
provides advice and is compensated by fee or commission for
doing so and who has a responsibility to serve my

However, most of the general public and the middle and upper middle class that I have and do serve, still does
not. They believe that the person or institution, be it a
Stock Broker, Financial Advisor, Investment Advisor,
Financial Consultant, Financial Planner, Bank Advisor
whatever the given title is who either recommends or
handles a order for them, is indeed the person to who they
have and will look to for ...ADVICE and who serves their

The public must be provided clear protection by the law so
that all persons or entities who ...render any investment
advice for a fee or commission are required to adhere to
the higher standards of the Investment Advisers Act of
1940. The disclosure of fees, conflicts of interest,
disciplinary information, etc., is clearly the most
appropriate way to serve the public. Accountability is
never wrong for the client.