Subject: File No. S7-06-04
From: Paul A Koeniguer
Affiliation: American Express Financial Advisors, Inc.

March 30, 2005

I recommend that the NASD withdraw the proposed rule... for some of the following reasons.

I have worked in the financial planning industry, with the same company for 20 years. I am fully licensed. Approximately 50% of my clients are retired.

Clients work with me and my colleagues because they need advice and solutions concerning their financial issues. As an industry I believe we all work from a high level of trust and help our clients in their decision making process. All my clients know all the investments I offer have some kind of fee and expect me to earn a living. They understand there is no free lunch. They do not come to me looking for the lowest fees. They are interested in advice. If compensation is not paid to advisors by the investment companies there is no incentive to provide service to the client unless you are a fee based advisor and charge fees based on net worth...plus the fees those clients must pay when they invest...

We disclose all our fees, all the various regulators currently require adequate fee disclosure, our company requires fee disclosure above the regulators requirements. Recently I have had clients tell me are required to sign off on more disclosures and documents than when they bought or recently re financed their home. It takes longer to complete the paperwork than it does to do the needs analysis. As I study the new proposed disclosure rule it only seems to duplicate what we currently have, duplicate what we currently have, duplicate what we currently have.

I believe in disclosure, I provide disclosure, however, I believe we have enough. Many clients believe we have to much...they tend to become confused by all the current duplication. Excess duplication tends to aggravate and cause mis-trust.

It is time to focus on overall returns, tax efficiency, more uniformity in the current prospectus disclosure, CLIENTS NEEDS, CLIENT SERVICE...

Let's help the client solve their financial issues in a prudent, responsible, easy way.

FOCUS MORE ON ENFORCEMENT FOR THOSE WHO DO NOT FOLLOW THE CURRENT RULES.

SPEED LIMITS AND SPEED LIMIT SIGNS DO NOT KEEP PEOPLE FROM SPEEDING...ENFORCEMENT DOES.

Thank you for your consideration of my views and the consideration of my clients.

Sincerely,

Paul A Koeniguer
Financial Advisor
American Express Financial Advisors, Inc.
IDS Life Insurance Company

American Express made the following
annotations on 03/30/05 15:46:28
-----------------------------------------------------------
***********************************************************

"This message and any attachments are solely for the intended recipient and may contain confidential or privileged information. If you are not the intended recipient, any disclosure, copying, use, or distribution of the information included in this message and any attachments is prohibited. If you have received this communication in error, please notify us by reply e-mail and immediately and permanently delete this message and any attachments. Thank you."

************************************************************
============================================================