Subject: File No. S7-06-04
From: Robert Geiler

April 19, 2004

The proposed rules on #33-8358 raises many issues from major policy considerations to technical logistical problems. I have been a registered representative working as an independent contractor for several years. I would respectfully request that the Commission:
1.Extend the comment period tp 180 days to give ample time for analysis and comment by all interested parties
2.Realize the complexities and burdensome tasks they are proposing to place on member broker-dealers who represent the independent contractor registered representatives who generate over 7 billion in annual gross revenues would require inestimable costs in dollars and other resources
3.Realize that the proposed required disclosures would only to serve to heighten the confusion of an already totally confused investing public that is in dire need of competent investment advice
4.Not approve the proposed rules.
Respectfully submitted,
Robert Geiler