Subject: File No. S7-25-99
From: Steven Wachs
Affiliation: CFP

September 8, 2004

I believe that the SEC should withdraw its rule exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs.

Having a different standard or policy for two distinct groups offering the same service does not offer the investing consumer adequate protection. Further, it weakens the standard of fiduciary duty owed to our clients.

Please reconsider the stance that you have taken.