September 25, 2002

TO: Files
FROM: Daphne Tippens Chisolm
Counsel to Commissioner Goldschmid
RE: Release Nos. 34-42099; IA-1845; File No. S7-25-99

On September 18, 2002, Duane R. Thompson and Robert Barry of The Financial Planning Association (FPA) and Roy T. Diliberto, a current member of the national Government Relations Committee of the FPA and a past president and chair of the FPA Board of Directors, met with Commissioner Goldschmid and Daphne Chisolm, counsel to the Commissioner. The discussion concerned the Commission's proposed Investment Advisers Act Rule 202(a)(11)-1. (see Certain Broker-Dealers Deemed Not To Be Investment Advisers, Release No. IA-1845 (Nov. 4, 1999)). Messrs. Thompson, Barry and Diliberto expressed the views contained in the FPA's comment letters on the 1999 proposed rule. (see Commission File No. S7-25-99). The FPA also distributed the attached outline at the meeting.