Subject: File No. S7-25-99
From: Charles W Dolci
Affiliation: Owner - CWD Consulting, Inc.

February 5, 2005

It seems to me that the SEC is trying to reduce its workload that would be caused by the additional filings required under the 1940 IA Act.

The SEC first position is to protect the investing public, who right now is confused as to the responsiblity of brokers and RIAs. Most of the general public beleive that the broker is a Fidiciary just like the RIAs.

The Merrill Lynch rule will memorialise this misunderstanding.

How is the SEC protecting the general public with this rule? If the SEC continues on this path some activist group will sue them.......... and win.