Subject: File No. S7-25-99
From: Lawrence H Friedrichs, CPA, CFP
Affiliation: AICPA, FPA, ASCPA, Alliance of Cambridge Advisors

August 26, 2004

As a professionally trained individual with average intelligence and a degree of common sense, I find it difficult to understand how the SEC could entertain a situation that allows lower standards under NASD suitability rules and a higher standard for Registered Investment Advisors.

This situation is especially disconserting in light of the problems caused by NASD governed brokerage firms - 1.4 Billion in fines - without admitting guilt give me a break.

Registered Investment Advisors already have a higher standard. They were not involved with the problems that urged the SEC to propose this new rule. Why are RIAs being burdened with these new rules?

There are only two possible explanations:

1 The brokerage industry has infiltrated the SEC.
2 The SEC is out of touch with reality in a world it is supposed to make better for the consuming public.

I urge the SEC to withdraw, not amend, this rule proposal. Please put your common sense hats on, stand up straight and make the right decision for those that you are trying to protect - the consumer of financial services.

If nothing else, watch the TV commercials being aimed at the American public by brokerage firms that have fought taking on fiduciary responsibility in dealing with the investing public. Their slick ads show brokerage firms walking hand in hand with the consuming public towards financial security. WHY NOT MAKE THEM FIDUCIARIES THE SAME WAY THAT REGISTERED INVESTMENT ADVISORS ARE CONSIDERED FIDUCIARIES? Advisors that have their clients best interest in mind embrace this responsibility. Why dont NASD firms? Gosh, then they might actually need to employ professionals instead of salesmen. What a pity for the investing public.

Do the right thing - kill this rule