Subject: File No. S7-25-99
From: Thomas G Buresh, CPA, CFP
Affiliation: VP, Suby Von Haden Assoc., S.C.

February 2, 2005

Re proposed rule S7-25-99:

Any broker dealer/representative that offers advice is doing just that, and should be required to comply with all requirements of RIAs and the 1940 act.

Full disclosure is mandated by ethics and consumer surveys.

Terminology used by broker dealers to describe their representatives can also be misleading. Many say they are financial advisors which implies the 1040 act applies.