Subject: File No. S7-25-99
From: William D. Starnes
Affiliation: NAPFA, FPA

February 1, 2005

The advertising on television promoting brokerage firms as personal financial advisors blurs any possible distinction in the publics mind between a broker and a financial advisor.

SEC definitions and brokerage firm disclosure are not going to be successful in clearly separating a broker exempt from registration from a financial advisor NOT exempt from registration.

Brokers use the peception that they are trusted financial advisors to sell products.

I feel strongly that the public will be very confused by their broker wearing two hats: one where he/she is a financial planner with a fiduciary responsibility, and then in the next moment, he/she is a broker that is going for the jugular -- fiduciary responsibility be damned.

In summary, the best solution is to have brokers register as financial advisors and provide complete compensation disclosures in their Form ADV, Part II, or equivalent brochure.