Subject: The Merrill Lynch Rule,  Release Nos. 34-42099 and IA-1845; 
 
Date:    04/12/2000 4:16 PM   
     
     
     
Mr. Jonathan G. Katz
Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549-0609
     
Re:  Release Nos. 34-42099 and IA-1845; File No. 
S7-25-99; Certain Broker Dealers Deemed Not To Be 
Investment Advisers
     
As a fee-only financial advisor who truly believes that the public deserves 
and can get neutral third-party financial advice, I've got to object to the 
Merrill Lynch rule.  If giving investment advice is only incidental to their 
business, they ought not be allowed to advertise it as a central benefit. 
Incidental implies minor, small, or insignificant, not the focus of a 
nationwide advertising campaign.  
     
The big brokers are hornswoggling the public again.  Make them come clean. 
Make them play by the same rules the rest of us do.   Or require them to tell 
Mary and John Q. Public that advice is only an eensy - teensy part of what 
they do - merely incidental.  After-all, that's what they are telling you.
     
Gracias,
     
Vincent P. Emmer, CFP
President
     
Forestis Financial Analytics, Inc.
P.O. Box 129
Evergreen, CO 80439