Subject: File No. S7-25-99
From: William M Harris

January 16, 2005

If the brokers want to be fee based planners, just make them register and choose a compensation path. Why is that so difficult? The financial services industry keeps getting blemishes because of the gray areas. Eliminate the gray area. You are either compensated by commissions or fee, but not both.

Years ago, I chose to file an ADV. I wanted to remove any institutional compromise from my business model. Its very clear. I have a fiduciary duty to work for my clients best interest. Brokers work for their institution, and have a legal/loyal responsibility to work in their respective institutions best interest. And, in that case the clients best interest may be incidental.