Subject: File No. S7-25-99
From: Robert W Eichten
Affiliation: Director, Financial Planning and Practice Management

September 17, 2004

Please withdraw the Rule. Earlier this year, the president of our division came to our investment advisory practice from a broker/dealer. We have been reviewing the advisory process of the broker/dealer from which he came with our advisory process, including products and services offered to the consumer/clients. There are small differences but none in the general process, products and services that would be detected by the most savvy consumer/client. It is a travesty that there would be different rules and regulatory compliance for different businesses that provide essentially the same products and services for the same customer. This is akin to mandating safety regulations for companys that make cars, SUVs, and pick-up trucks but not for companys that make only pick-up trucks.