Subject: File No. S7-25-99
From: Channing F Mitzell, CFP
Affiliation: President, The Windsor Group, Ltd

January 21, 2005

The Merrill Lynch rule is a joke...on the American Consumer.

Why? An INDEPENDENT RIA is to act as a fiduciary for his client-putting his clients interests ahead of his own. This is further documented by submitting Form ADV to the SEC whereby the RIA discloses all conflicts of interests and all sources of compensation - required under the Investment Advisor Act of 1940. The INDEPENDENT RIA gets paid a fee directly from the client.

Now, when I got into the business working with a large Broker/Dealer in the 80s, I received a w-2 and got paid by my employer. I needed to make my employer and my boss money so that I could make more in my w-2. I did not HAVE to act in a fiduciary capacity to my clients because I am selling financial widgets to make my employer money. Further, I was not required to disclose exotic trips because of my sales nor financial incentives to sell my employers proprietary products.

Yeah, that seems like a level playing field---are you kidding me????