Subject: File No. S7-25-99
From: Abbas A Heydari

September 16, 2004

My name is Abbas A. Heydari 12 years ago I earned my CFP designation and currently have a financial planning practice in Torrance, Ca. I was a registered representative with an independent broker / dealer firm for 15 years which I terminated on May 1st, 2003.

I strongly oppose allowing brokers who give investment advice as a material part of their relationship with clients to be excused from compliance with the requirements that all other investment advisors must meet.

Today, brokerage firms advertise that they provide a breadth of financial planning and investment advice to help clients meet their life goals. Their pictures and words in large print show and say this. They suggest that they do nearly anything and everything across the range of financial planning, investment advice, and investment portfolio oversight and/or management.

To excuse any financial planner or investment advisor from registration and meeting the minimum requirements of a RIA, just because of where he or she may work, is inexcusable. Not only would this be unfair to the client, no client would understand this to be possible, especially in the era of expected greater fairness and honesty.

I would like to propose SEC rescind the Merrill Lynch Rule in its entirety.

Thank You,

Abbas A. Heydari, CFP