From: Bob Keats [BobK@Keatsconnelly.com] Sent: Monday, June 24, 2002 5:45 PM To: rule-comments@sec.gov Subject: Proposed Rule- Certain Broker-Dealers Not to be Investment Advisors This "Merrill Lynch" rule is one of the worst possible set backs to consumer protection in the financial industry at a time when a boast in consumer confidence is sorely needed. The large brokerage firms hold themselves out as comprehensive financial advisors in all their advertising so consequently consumers should expect that the brokers are being held to fiduciary standards required by all those already holding themselves out as providing the exact same services but who are regulated by the SEC RIA rules. If it looks like a duck, walks like a duck, quacks like a duck lets call it a duck, if you don't, by allowing this rule, you are setting the American consumer up for even a bigger fall than the crisis we are currently going through. Robert F. Keats CFP, MSFP, CFP (Canada) Keats, Connelly & Associates, Inc. 3336 N. 32nd Street, Suite 100 Phoenix, AZ 85018 Phone: (602) 955-5007 Fax : (602) 224 5874 E-mail: bobk@keatsconnelly.com Web site: www.keatsconnelly.com