Subject: File No. S7-25-99
From: Brian R Carlton, CFP

August 25, 2004

Dear Sir or Ms of the SEC,
This concerns the so called Merrill Lynch rule. Please for the benefit of all financial consumers withdraw this rule. It is absolutely in error and needs to be canned.
The rule is harmful to consumers by creating two different standards of conduct for persons offering financial
planning services: a higher fiduciary standard for registered investment advisers and a lower one under NASD suitability rules. The rule also exempts, in
effect, brokers from being required to disclose conflicts of interest in connection with the offer of financial planning services.
The public deserves much better than this. The brokers certainly act like they offer financial planning and should be held to the same standards.

I appreciate your attention to this matter and again ask you to withdraw this rule asap.

Brian Carlton CFP