Author:  Milton Kuninsky 
Date:    06/13/2000  2:22 PM

Subject: File No. S7-10-00

We would like to take this opportunity to comment on the proposed amendments to 
Form ADV.
     
We believe the electronic filing and the proposed revisions of Form ADV are very
positive steps.  We commend the SEC for moving forward in this direction.  Our 
comments are directed at the increased accessibility of detailed information to 
the general public (which includes competitors) on how an investment adviser 
conducts its business and how its fees are structured.  
     
We are in agreement with the proposed requirement in Part 2A, Items 4 and 5 that
would require detailed information on how an advisor conducts business and how 
they are paid, but only as it pertains to client disclosure.  It has been and 
always will be our firm policy to fully disclose this information to our 
clients.  
     
We believe that it is not sound business practice to require the same level of 
disclosure to competitors, as is required for our clients.  We understand how 
difficult this is to accomplish.  It does not, however, seem appropriate for 
competitors to see specific procedures and fees of competing firms.  In fact, it
almost smacks of anti-trust issues.    
     
We suggest the detailed information on how a firm conducts its business and how 
its fees are structured be accessible in the same manner as the SEC proposes for
Part 2B