Subject: File No. S7-25-99
From: Thomas A Grose, CFP

September 16, 2004

Please withdraw the above Rule proposal for the following reasons:
By eliminating special compensation as a critical element in the contractual relationship, the Rule permits stockbrokers to misrepresent their fundamental sales role as one of a fiduciary adviser receiving a fee for advice. Further, it places financial planners at a competitive disadvantage by allowing brokers to market similar programs under less rigorous regulatory standards for disclosure and advertising.