Subject: File No. S7-25-99
From: Thomas C. Pritchett, CPA, PFS, CFP, APM
Affiliation: Managing Partner, APB WealthCare Advisors, LLP

January 25, 2005

The exception should not be available to broker-dealers who hold themselves out to the public as investment advisors or financial planners. Doing so would be misleading to investors and limit the full disclosure that the general public should be entitled to.