Subject: File No. S7-06-04
From: Geoffrey L London
Affiliation: Mutual Service Corp. financial advisor

April 1, 2005

I am opposed to two parts of this proposal. First, you are rushing it through with an inadequate comment period. Do you not want candid feedback? Please extend the period for 30 days.

Second, this is far too burdensome for an industry that is already beset by over-regulation. It will cost too much for reasonable compliance and require too much more manpower and paper in comparison without the benefit actually received by the public. It will be as bad - as much overkill - for the securities industry as Sarbanes Oxley is for public corporations.