From: Marti Thomas [Marti@hcm3.com]
Sent: Monday, June 24, 2002 10:35 AM
To: rule-comments@sec.gov
Subject: File No. S7-25-99

Ladies and Gentlemen:

I am writing to urge you to withdraw the proposed rule, "Certain 
Broker-Dealers Deemed Not To Be Investment Advisers."  The Investment 
Advisers Act of 1940 and the rules thereunder have been crafted and honed 
over a number of years to impose disclosure and fiduciary requirements 
on  Investment Advisers.  These requirements have raised the level of 
protection of advisory clients and the standards of the advisory 
profession.  Allowing broker-dealers to offer financial planning advice 
without imposing the rules that have been tailored specifically for the 
investment advisory profession and its clients would be a grave mistake.

Very truly yours,

Martha Q. Thomas
General Counsel
Horizon Capital Management, Inc.
Lafayette, Louisiana