Subject: File No. S7-25-99
From: William F. Muhs, Ph.D.
Affiliation: President, Montvest

September 13, 2004

I strongly urge the SEC to WITHDRAW the SEC Broker-Dealer Rule Exemption. After having spent 23 years in academe as a business professor I started my fee-only RIA business ten years ago. During this period I have talked to dozens of prospects who have suffered greatly as a result of unprofessional behaviors by non-RIAs. The lack of basic fiduciary responsibility in many of these cases is quite frankly, appalling. The problem became exacerbated during the market downturns in 2000. Many people saw there wealth decline by fifty percent or more Their brokers typically passed this off as market risk. In fact, a well diversified portfolio across most asset classes should not have lost much value in 2000-2001. Clearly, two different fiduciary standards have existed with damaging results. I cannot imagine a modern, capitalist economy that permits commission based sellers of securities to avoid full disclosure of conflicts of interest. Consumers are terribly confused by the existing terminology of those who offer financial planning and/or investment advice. Please, for the future of America, withdraw S7-25-99. Thank you.