Subject: File No. S7-25-99
From: David B Jacobs, Ph.D.
Affiliation: President of Pathfinder Financial Services, LLC

September 7, 2004

Wirehouses are advertising themselves to the public as financial advisors. Their marketing is so strong in fact, that I have yet to meet a single client who understood the difference between a registered investement advisor and a financial advisor at Merrill Lynch until I explained it to them.

It is high time that if someone holds themselves out as a financial advisor they should be required to register and be held to the same fiduciary standards as all other registered investement advisors.

From Merrills web site here is their description of their wealth management process. It sure looks like they are putting out to he public that they are investment advisors not simply stock brokers. The following is from

Our Wealth Management process is the engine your Financial Advisor uses to deliver Total Merrill. This process brings together our entire breadth of services and helps you and your Financial Advisor tailor solutions based on your goals and risk tolerance.

Merrill Lynchs comprehensive planning services to support the Wealth Management process include:
Assessing Your Goals
Allocating Your Assets
Financial Foundation Report
Specific Issues/ Modular Needs
Financial Foundation Update Report
Interactive Financial Foundation
Premier Wealth Plan

This clearly goes way beyond advice incedental to the sale