Subject: File No. S7-25-99
From: Richard A Hutchinson, MBA, MA, CFP
Affiliation: Principal, Dick Hutchinson Reg Inv Adv

January 23, 2005

I am an individual RIA - Connecticut regulated - associated with a broker/dealer. I am responsible for all regulatory requirements as an investment advisor, as well as branch manager/rep of a broker/dealer.

Unlike the brokers at Merrill who hold themselves out to the public as Financial Advisors, as Registered Invesmtnet Advisor reps, without being required to abide by Investment Advisor Regulations as stipulated in the Investment Advisors Act of 1940, I have to abide by the regulations, in total.

Obviously this is unfair, reflecting the SECs bias towards assisting large broker operations to the detriment of the small business operations, the public and the legislated law.

Please, the SEC has to reverse this position...anyone operating as a registered investment advisor should be made to abide by the regulations.