Subject: File No. S7-25-99
From: Stephen S. Overstreet
Affiliation: NAPFA Member

February 4, 2005

The re-proposed rule does not satisfy the main issue for consumers: if a broker-dealer wants to give advice that goes beyond the traditional buy this, sell that because, then it should register under the Advisers Act.

Investors today do not understand the significant difference between a broker and an investment advisor. Investors expect but too frequently are not getting impartial advice from brokers. Protection of investors is a vital SEC role, and this role is not sufficiently reflected in the revised rule. How can we even consider privatizing Social Security when the investing deck is stacked against the investor who has no/ little education in this vital area and then gets tainted advice when he seeks it?

The alternative should be mandatory investment education courses from high school on in this country. The SEC should be leading this effort, not fighting it.