Subject: File No. S7-25-99
From: Robert Thomas
Affiliation: President CEO Vantage Investment Advisors, LLC

August 24, 2004

I want to comment on the rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs. I believe the rule is confusing and harmful to consumers by creating two different standards: a higher fiduciary standard for registered investment advisers and a lower one under NASD suitability rules. Consumers trust their assets with both brokers and investment advisers, and thefefore, the higher standards should apply to both.