Subject: File No. S7-25-99
From: John P Carrig, CFA, CFP

September 18, 2004

When I started out in financial services business over 30 years brokers were called registered reps then financial consultants and now financial advisors. Yet, they are still regulated by the NASD and not by the SEC under the Investment Advisors Act of 1940.The majority have a minimum amount of training and their compensation is based on commissions.
If they want to offer comprehesive planning and offer their serivices as fee-based, they should be held to higher standards that fee-only planners like myself are required to follow.
I believe the ML temporary rule is harmful and confusing to consummers. If brokers want to offer financial planning services, they should be held accountable to higher fidicuary standard for registered investment advisors.