Subject: File No. S7-25-99
From: Frederick F Kramer, JD
Affiliation: CIO, Wealth Advisor Group LLC

September 8, 2004

For the first 15 years of my career, I was with a major securities firm. For the last 8 years, I have been a partner in a fee-only registered investment advisory firm. Contrary to what some may like you to believe, these two jobs were vastly different. In fact, the reason for the career change was precisely because they were so different that I believed it was impossible to function in the best interest of the client by remaining with the wire house. You have already heard numerous responses from a wealth of people telling you that the Merrill Lynch Rule is counterproductive...perhaps not to Merrill Lynch, but certainly for those people that you should most be concerned about -- the clients. If indeed, brokers or any other name they may choose to call themselves want the same relationships as I have with my clients, then they should be held to the same standards. Anything less would be adding fuel to the fire of potential conflict of interest and/or appearance of impropriety.

Thanks for this opportunity to submit my comments.