Subject: File No. S7-25-99
From: Sherman L. Doll, CPA/PFS
Affiliation: Capital Peformance Advisors

January 31, 2005

I am writing concerning the proposed broker-dealer exemption from registration as an RIA. The public is not well-served when brokers are allowed to give financial planning advice without the same rules and restrictions as RIAs. If brokers are solely executing transactions, then I can understand the exemption. But, indeed most brokers hold themselves out as financial advisors and their advice is more than incidental to their transaction activities. This provides an uneven operating environment in the investment advisory industry. The rules should be the same for all advisors, or brokers should be prohibited from giving financial advice.