Date:    04/12/2000  4:17 PM

 Subject: Merrill Lynch Exception
     
     
     
Re: Release Nos. 34-42099 and IA-1845; File No. S7-25-99; 
Certain Broker Dealers Deemed Not To Be Investment Advisers
     
     
Your intention to give an exception to the investment advisor disclosure 
rules for wirehouse firms seems a little abrupt and obvious, if not 
outrageous.  If you are going to alllow some member investment advisors to 
compete on  an unequal playing field by creating two levels of disclosure, 
I suggest that you tilt the rules a little in the direction of the "small" 
firms and let the large firms work a little harder to get the special 
status they and their Washington lawyers require.  With nearly unlimited 
funds, I know they will eventually get their concessions and force their 
monopoly on the consumer through the special status they have with the 
government, but you are making their victory too easy with this two-tiered 
regulation.  Please slow down the inevitable for the good of the 
profession, the consumer, and the government.  This is too cheap a bargain 
and too obvious.
     
If you are unmoved by my suggestion for fairness, at least go slower.  My 
partners and I are in our 50's.  We would appreciate it if you wait another 
ten years before giving the IA business to the wirehouses through unequal 
regulation.
     
Sincerely,
     
Kevin P. Condon, Ph.D., CFP
Principal
Baltimore-Washington Financial Advisors, Inc. 
3525 Ellicott Mills Drive, Suite G
Ellicott City, MD 21043
410-461-3900
Vice President, NAPFA (National Association of Personal Financial Advisors) 
Northeast Board, Past President Maryland ICFP (Institute of Certified 
Financial Planners), Director of Programs, FPA (Financial Planning 
Association) of Maryland.