Subject: File No. S7-25-99
From: Paul R Pignone, CFP, CLU, ChFC, AIF
Affiliation: NAPFA

September 7, 2004

I ask you to please reconsider and rescind the NASD exemption and the Merrill Lynch Rule. I have over 25 years experience in the Financial Services Industry and have worked for Insurance Companies before and during my time as a Financial Planner and Registered Investment Advisor. I know how they train agents to market their services to their clients. The market is already confusing consumers regarding who is Fee and who is Commssion. Recently on an Audio Business Card, the agent actually said that the commission life insurance product is no load even though he is paid a Fee from the Company....not a commission. I sent the tape to the New Hampshire Securities division.
I ask you to refer the the B/D websites, advertising literature and marketing material for examples. There is no doubt theyre trying to hide how theyre paid.
Please do this for the consumer, particularly, the Senior Citizens who are continually taken advantage of by Annuity Selling reps.
Thank You

Paul Pignone
Boston Retirement Advisors, LLC