Subject: File No. S7-06-04
From: Rachelle L Nelko
Affiliation: CSA

March 30, 2005

If this is allowed to happen, many broker-dealers will need to pass the cost down to independent representatives that will no longer be able to afford to offer their clients securities products. This should not be a goal of the SECs to force out the valuable independent representatives that work face to face with their clients every day and provide them with the best level of advice and service that they can. This will create many valuable hours in administration work, that would be much more wisely spent in providing valued client service and investment education.

Why should the independent representative take full responsibility, when there is a team that assists with the sale; starting with the issuer company that must take responsibility?