From: B. Michael Muirhead
Sent: March 30, 2005
To: rule-comments@sec.gov
Subject: File No. S7-06-04

To Whom It May Concern:

I am a registered representative and have held my license just over 6 years. The idea of disclosing all fees to clients is one that I strongly oppose. Currently I am required, if asked, to provide that information to my client. However, I feel it is an infringement if I were to be forced on every occasion to provide written documentation for the services I provide. There are at least two reasons for this. The first is the fact that the gross commissions do not reflect ‘how much I make’. The client does not see the expense side of my business (and frankly doesn’t care). In fact, last year, the expenses of my business ran 40% of the total gross revenues before taxes. After taxes, that figure will be less than 50%, but the client will see only the income side of the equation. Secondly, I can think of no other business that is required to disclose how much they make on transactions…..not plumbers, electricians, car dealers, and on and on. Why should we?

We are in a highly regulated business with levels of oversight rarely seen in other businesses. By a far majority, the business transacted in the arena of securities is in the best interest of the clients involved. I live in a small town and any inkling of impropriety will be the end of my business. I want to do the best for my clients and cannot afford even the hint of failure to do so. In addition, the prospectus that we are required to give to the client for each securities purchase already has lengthy discussions of fees and expenses.

Please do not paint all with the same brush. There are instances when the few have spoiled it for the many, but the action being considered by "File No. S7-06-04" is going too far.

Thank you for your time and attention to this very important matter.

Sincerely,

B. Michael Muirhead

Financial Partners
807 8th Street, Suite 300
Wichita Falls, Texas 76301
940-322-6277