The largest brokerage is sticking to an on-line strategy that distinguishes it from proponents of low-cost Internet trading.

Merrill Lynch & Co. continues to promote personal relationships with on- line customers-a choice that entails most or all of the costs of regular brokerage services.

John L. Steffens, vice chairman and head of the U.S. private client group, said the firm wants its legacy to be: "We got it. We were right. The integration of technology and human beings is the most-effective Internet platform."

Merrill is "keeping its fingers crossed" with this approach, Mr. Steffens said in a speech to a Forrester Research conference last week in New York.

One element of Merrill's on-line goal is to raise on-line advice "to a whole new level," he said.

Recently, for example, Merrill began offering advice over the Internet to 401(k) investors. Use of this electronic service is growing at 30% to 35% a week, Mr. Steffens said.

By enabling consumers to do research and perform their own asset allocations on-line, Merrill frees its brokers to concentrate on high-net- worth people, said Daniel Burke, senior analyst at Gomez Advisors, a Concord, Mass.-based e-commerce advisory firm.

Merrill has offered advice on its Web site since 1994 and plans to make more research tools available, Mr. Steffens said.

Even as it adds to the "excessive amounts" of information available on the Internet, Merrill contends that human judgment will become more important than ever, Mr. Steffens said.

Clients too busy to manage their own investments will require advisers, while others will want to talk to Merrill people as "sounding boards," Mr. Steffens said.

The firm offers on-line trading capabilities only to clients who have at least $100,000 in either of two accounts, Asset Power and Financial Advantage Service. These customers are charged annual flat fees based on the assets held.

Mr. Burke of Gomez said Merrill has a winning approach. Its average on- line trading account holder has about $320,000 invested-triple the amount at Charles Schwab & Co., he said.

"Those people will be willing to pay extra for meaningful advice," Mr. Burke said.

Mr. Steffens said Merrill is evaluating how an extended on-line trading service might be priced. It is more likely to be fee-based than commission- based, he said.

Mr. Steffens said about 19 million people in the United States have investable assets of $100,000 or more; that is expected to climb to 40 million by 2003. The number of people with more than $1 million to invest could grow as high as 25 million by 2005, he said.

That amount of wealth would not be sustained if everyone became a "day trader," Mr. Steffens said.

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