From: Thomas Adams [teadams@earthlink.net] Sent: Friday, January 23, 2004 5:00 PM To: rule-comments@sec.gov Subject: (s7-04-04) Reaction to proposed rules Dear Sirs: Concerning the proposed "Investment Advisers Codes of Ethics" [S7-04-04): First, an obervation: when my wife and I discovered a problem (stealing) with out investment adviser, I called your office and was told that there was little you could do. We solved the problem ourselves by firing the firm involved. More fundamentally: a long list of new rules will solve nothing. In order to change the culture of stealing that currently exists, you must do more, such as: 1) Eliminate Class B & C mutual fund shares. 2) Lower the maximum 12-b1 fee to 0.25%. 3) Investigate the practice of selling annuity contracts with surrender charges (and multi-year surrender periods) to our senior citizens. 4) Require everyone who calls themselves "financial planners" or "investment advisors" to abide by the rules that CFP credentialed people and RIAs must already adhere to. In fact, someone who calls himself/herself a financial planner should be required to obtain the CFP credential. 5) Require the disclosure of how every planner, advisor, salesperson, and their companies are paid. This should be either via a contract that spells out how the client is paying, or, to the extent possible, what the actual costs will be. If the SEC and NASD don't have the guts to eliminate B and C shares, disclosure of up front and annual trail commissions should be required disclosures. 6) Require all registered reps, including bank salespersons and their supervisors, to complete annual training in what it means to be a fiduciary. This would include why some products are not just wrong for certain consumers, but why they are also unethical and should not be allowed. Sincerely, Thomas E. Adams 20 Devon Avenue Lawrenceville NJ 08648