Subject: File No. S7-25-99
From: F. Dennis De Stefano, CPA CFP

August 23, 2004

I urge full repeal of the so-called Merrill Lynch rule.

The rule as currently in effect is supposed to only allows brokers to give advice as incidental to their work as brokers. Yet their advertising and brokers themselves indicated that not only do they provide investment advise but that they are qualified to provide the full range of non-investment financial planning services goal setting, insurance needs analysis and planning, cash and debt management, estate planning, retirement planning, tax planning, education planning and so on.

The financial service industry is now referring to their sales force as financial advisors or financial consultants and moving to a fee-based approach to delivering financial products and services. Nevertheless, it is important to understand that Fee-Only Planning is not only a fee-set it is also a mind-set and a skill-set. Without more, merely changing a salesmans title or the way he is compensated does not alter his transaction oriented mind-set nor enhance his skill-set.


F. Dennis De Stefano
Registered Investment Adviser
NAPFA-Registered Financial Advisor