Subject: File No. S7-25-99
From: William S Hrank, RFC, CGFM
Affiliation: Financial Planning Association

September 20, 2004

Regarding the SEC Broker-Dealer rule exemption - As a Registered Financial Consultant and Registered Investment Advisor I urge you to WITHDRAW, not amend, the rule proposal. I believe the rule is harmful to consumers by creating two different standards of conduct for persons offering financial planning services: a higher fiduciary standard for registered investment advisers and a lower one under NASD suitability rules. The rule also essentially exempts brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.