Subject: File No. S7-06-04
From: Andrew C Kupferberg C Kupferberg, CPA

April 4, 2005

The adoption of these proposed rules may have substantial unintended consequences for independent broker/dealers and their registered representatives. Of primary concern is that complying with the proposed rules - principally the creation and maintenance of the point of sale disclosure - will be so extremely burdensome and costly that broker/dealers will be forced to limit significantly the number of Covered Securities approved for sale.