Subject: File No. S7-xx-04
From: Kevin B. DeLacy

July 22, 2004

From: DeLacy, Kevin B.
Sent: Thursday, July 22, 2004 8:46 AM
To: Donaldson, William H.
Subject: Incidentally, Let's Call Them Investment Advisers

Dear Mr Chairman

Here is something I think you should look into. This five year old proposed rule should not be adopted. The Commission as the investor's advocate should not allow brokers to be called financial consultants (see Merrill Lynch - and then not be held to the standards of the Advisers Act.

Thank you for your consideration