Subject: File No. S7-25-99
From: David L Frank, CFP, CIMA, AIFA
Affiliation: Financial Planner/Asset Manager/ Broker

September 21, 2004

Brokers are in the business of giving advice to their clients. That is what they sell. for 20 years I have been told by my employers, and have told my brokers that we give advice to clients to help them meet hteir goals. Brokers/dealers need to be held to the same Fiduciary Standards as managers and financial planners. The advice that we give is not incidental to the sale of securities as merril lynch states. At this point in time it is the advice that we sell.

We should be held to fiduciary standards