Subject: File No. S7-25-99
From: Howard A Townsend, CFP

September 9, 2004

It is difficult for me to comprehend why independent advisors as well those affiliated with a B/D must be registered in order to offer separate accounts or charge for plans, but a Merrill Lynch wants to be exempt How ridiculous is this All their advertising talks about planning and advising They put their clients into separate accounts with exorbitant fees They do so-called financial plans and risk profiles. What makes them different? The only thing that comes to mind is their money and lobbying.

Do the right thing and create a level playing field.

Yours truly,
Howard Townsend, CFP CLU ChFC