From: Julie Gebert [jjgebert@unitedplanners.com]
Sent: Wednesday, March 03, 2004 5:00 PM
To: rule-comments@sec.gov
Subject: S7-06-04

Dear Mr. Katz: 

United Planners Financial Services of America is a Broker/Dealer located in 
Scottsdale, AZ that services approximately 400 Registered Representatives, the 
majority of which are also dually registered as Registered Investment Advisors. 
 UPFSA is licensed  in all 50 states and has been in business since 1987.  
 UPFSA is a subsidiary of Pacific Select Distributors (PSD) which is owned by 
 Pacific Life Insurance located in Newport Beach California. PSD also owns four 
 other broker/dealers throughout the country. 

We are very interested in responding to the above-captioned  proposal, however 
we believe there are many complex issues contained in the proposal that will 
require broker/dealers to perform a detailed analysis of the extensive proposed 
changes and the possible ramifications to their respective firms. 

We therefore request the Commission  extend the comment period at least 180 days 
beyond the original comment period to give the industry ample time for analysis 
and thorough investigation.

Respectfully,

Julie Gebert
United Planners Financial Services of America
Vice President
Phone: 480-991-0225 ext. 214
Fax: 413-683-6918
jjgebert@unitedplanners.com


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