Subject: File No. S7-25-99
From: thomas a gafford
Affiliation: Owner, Gafford Technology

September 24, 2004

I see no reason why brokers for large security houses should operate under different rules than individual financial advisers. If some form of the Merrill Lynch Rule is going to be adopted, then anyone who is not bound by the fiduciary rule should NOT be able to represent themselves as anything other than Salesperson.

advisor is an unnacceptable title for someone not bound by the fiduciary rule.

Further, anyone who offers securities for sale and is not bound by the fiduciary rule should be required to say that they are not so bound to the potential customers whom they contact, and there should be penalties for any such sales person who represents themselves as anything other than a sales person.