Subject: File No. S7-25-99
From: Robert J. Spindel, CFP
Affiliation: NAPFA Registered Financial Advisor

February 1, 2005

It is time to eliminate the Merrill Lynch rule and simply create a uniform standard of investor portection for all broker-dealers and investment advisers who porvide financial advice to investors. If youre offering investment advice and financial should be registered as an investment advisor. Issues of adequate effective disclosure and appropriate standards of care associated with fiduciary responsibilities can be clearly resolved by elinimating, not amending, the existing Merrill Lynch exemtion.