Subject: File No. S7-25-99
From: Stephanie Parlee

September 22, 2004

One particular gap that I would like to see addressed is the ability of a registered representative to avoid registration as an investment advisor representative by using the advice is incidental to the sale rule, while at the same time being allowed to use titles which connote the importance of the advice given (like financial planner and investment adviser).

Thank you,

Stephanie Parlee., CFP, EA