From: William Michael Cunningham
Sent: March 6, 2004
To: rule-comments@sec.gov
Subject: File No. S7-04-04


William M Cunningham, MBA, MA
Social Investment Adviser
Washington, District of Columbia
Email: info@creativeinvest.com

We understand that the US Securities and Exchange Commission will consider whether to propose new rule 204A-1 under the Investment Advisers Act of 1940 Advisers Act. The proposed rule would require investment advisers to adopt codes of ethics that would set forth standards of conduct for advisory personnel, safeguard material nonpublic information about client transactions, and address conflicts that arise from personal trading by advisory personnel.

We refer the Commission to the following:

The Eight Commitments of Ethical Culture
From the Philadelphia Ethical Society

1. Ethics Is Central - The most central human issue in our lives is creating a more humane environment.

2. Ethics Begins With Choice - Creating a more humane environment begins by affirming the need to make significant choices in our lives.

3. We Choose To Treat Each Other As Ends, Not Means - To enable us to be whole in a fragmented world, we choose to treat each other as unique individuals having intrinsic worth.

4. We Seek To Act With Integrity - Treating one another as ends requires that we learn to act with integrity. This includes keeping commitments, and being honest, open, caring and responsive.

5. We Are Committed To Educate Ourselves - Personal progress is possible, both in wisdom and social life. Learning how to build ethical relationships and cultivate a humane community is a life-long endeavor.

6. Self Reflection And Our Social Nature Require Us To Shape A More Humane World - Growth of the human spirit is rooted in self-reflection, but can only come to full flower in community. This is because people are social, needing both primary relationships and larger supportive groups to become fully human. Our social nature requires that we reach beyond ourselves to decrease suffering and increase creativity in the world.

7. Democratic Process Is Essential To Our Task - The democratic process is essential to a humane social order because respect for the worth of persons requires democratic process which elicits and allows a greater expression of human capacities.

8. Life Itself Inspires Religious Response - Although awareness of impending death intensifies the human quest, the mystery of life itself, and the need to belong, are the primary factors motivating human religious response.

We also refer you to our comments on corporate governance rules. The complete text of these comments is available on-line at:

Security Holder Director Nominations
Release No.: IC-26206
File No.: S7-19-03

Comments of William Michael Cunningham, Social Investment Adviser, William Michael Cunningham and Creative Investment Research, Inc.

http://www.sec.gov/rules/proposed/s71903/wmccir122203.pdf

Comments on S7-36-02: Disclosure of Proxy Voting Policies. Comments of William Michael Cunningham and Creative Investment Research, Inc.

http://www.sec.gov/rules/proposed/s73602/wmcunningham1.htm

Comments of Creative Investment Research on S7-10-03

http://www.sec.gov/rules/other/s71003/wmccreative050503.htm

Finally, please see:

Corporate Ethics - Given recent events, significant market reforms are needed. In several high impact cases, ethical principles have been abandoned in the pursuit of material well being.

http://www.creativeinvest.com/sri/corpeth.html

Corporate Malfeasance - Deceptive and fraudulent activities carried out by accountants, investment banks, brokerage firms and investment analysts.

http://www.creativeinvest.com/sri/corpmal.html

Frequently Asked Questions about financial market scandals.

http://www.creativeinvest.com/sri/corpmal1.html

Financial Market Reform - Things you can do to protect your money. How you can reform the markets.

http://www.creativeinvest.com/sri/corpeth1.html

William Michael Cunningham
Social Investment Adviser
Creative Investment Research, Inc.