Subject: File No. S7-25-99
From: Susan M John
Affiliation: CFP, NAPFA, FPA, Registered Investment Advisor

September 17, 2004

The proposed rule needs to be withdrawn. By creating two standards of conduct the rule promotes confusion that is detrimental to consumers. Since the introduction of this rule, large broker/dealers have taken advantage of it to orient advertising of their services as financial advisors, wealth counselors and financial planners. It should be obvious from these national advertising campaigns that these services are no longer incidental to their brokerage business.

Consumers do not understand the difference in disclosure requirements, conflicts of interest, and accountability standards or a distinction between normal brokerage services and an incidental service. Promulgating this rule, or failure to withdraw it, will serve to further set-up the general public to more abuses. We have had enough confusion and scandal in the industry in the last few years.