Subject: File No. S7-25-99
From: John H Cecil, Jr
Affiliation: Managing Director, Trendline Capital Management

September 8, 2004

SEC Commissioners:

In the best interest of all clients of investment advisory services, I respectfully request you to rescind the Merrill Lynch Rule in its entirety.

Having worked as an RIA principal for over 26 years, I call your attention to the blatant misrepresentation in advertising by the major brokerage firms regarding their advisory services. Should we registered investment advisers have fiduciary responsibilities for our clients and the so-called brokerage firm consultants have none?

It would unquestionably be better for you to rescind the Merrill Lynch Rule than for the financial services industry to suffer more scandals, potential lawsuits, and bad publicity than we have seen in the last few years.

John Cecil