Subject: File No. S7-25-99
From: Jeffrey E. Daniher
Affiliation: Ritter Daniher Financial Advisory, A Fee Only Registered Investment Advisory Firm

September 7, 2004

As a trust office by training, and now an independent financial advisor, acting as a fiduciary has been the only way that I have ever known when it comes to managing assets and offering advice to the public. To think that one group is exempted from this responsibility while being able to portray that they are indeed in the same business is a terrible shame. It would seem to me that holding all professionals to the same, higher, standard is in the best interest of the public. What good does it do to allow one group, with extensive marketing and lobbying power, the ability to appear to be intersted in the best interests of their clients when in reality they have no such duty? Shouldnt the consumer public expect that no matter who they choose to provide advice and counsel that they will receive unbiased advice? Shouldnt they receive advice and recommendations that are based on what is best for them as opposed to that which is in the best interest of the broker and for the firm that the broker works for?

Wirehouse firms should be required to register as Registered Investment Advisers under the 1940 Act, immediately and without qualification.

Please rescind the Merrill Lynch Rule in its entirety.