Subject: File No. S7-25-99
From: Nancy Scanlan, DVM, MSFP

September 7, 2004

I will be retiring from veterinary medicine after the next 5 years, and have just begun a career as a financial planner. I have chosen to become an independent advisor and not be affiliated with a brokerage house or broker-dealer precisely because I see the potential for a big conflict of interest when offering advice, but working for a firm that gives big commissions on some trades, and at least some commission on all trades. In addition, one of my professors used to work for Merrill Lynch, analyzing stocks and giving recommendations for their brokers. He retired early when he saw that they were, more and more often, recommending as trades the securities he most strongly recommended against.

If a person is going to call himself/herself an advisor, as all the big firms currently are advertising their brokers as doing, it is a major conflict of interest to both offer that advice and to sell individual items that have commissions attached. There is no way anyone can stay honest and truly have the interests of their client in mind. Salesmen exist to sell, not to advise. They are not counselors.

Any advisor should be held to the same standards as other investment advisors. Alternately, they should no longer be allowed to say or imply that they are anything else but securities brokers.