Subject: File No. S7-25-99
From: William Eichenberger, CFP
Affiliation: Owner, Harbour Pointe Financial Advisors, LLC

August 23, 2004

Re: Release Nos. 34-42099 IA-1845 File No. S7-25-99

I recommed that the SEC withdraw the above-referenced rule entitled Certain Broker-Dealers Deemed Not To Be Investment Advisers.

I believe that the public would be best served by having full disclosure of conflicts in all fee-based investment programs. Investors will benefit through consistant and comprehensive disclosure of conflicts and the related fiduciary protections provided by the Advisers Act.