Subject: File No. S7-06-04
From: Douglas K Shannep, CFP, CIMA
Affiliation: Managing Director

April 4, 2005

Please extend the comment period for at least 30 days because we have not had appropriate time to review the proposal. It appears this proposal may be burdensome and costly to independents like ourselves. We need more time to review the potential implications. Thank you for your consideration of my request.