Subject: File No. S7-25-99
From: William B Burns, Jr.

January 14, 2005

I am concerned about how the SEC would draw the line between financial planning services that are incidental to brokerage transactions and those that are not. I am not convinced this can be done in a matter that will protect consumers.

Wouldnt it simply be more effective, more efficient, and more fair, to have brokers and investment advisors subject to the same rules, not opening the potential conflicts involved with interpretation.

Thank you.