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.