From: Ray Ferrara [ferrara@provise.com]
Sent: Wednesday, July 17, 2002 12:02 PM
To: 'rule-comments@sec.gov'
Subject: File Number: S7-25-99

To Whom it May Concern:  Having been in the financial services business
since 1971, I have had the opportunity to view the transformation of the
business from one totally dominated by sales people, to one that is an
aspiring and growing profession called financial planning.  The consumer is
learning the value of holistic financial planning provided by ethical and
competent Certified Financial Planner professionals versus receiving biased
advice from sales people.  Especially given the current climate, where a
lack of disclosure, hiding behind financial planning to sell products, and
those who want to jump on the band wagon without paying the price, this is
totally unacceptable.  

For the past two and a half years, I have had the pleasure of serving on the
Board of Directors for the Financial Planning Association, and participated
in the recent unanimous vote declaring our opposition to the above
referenced item, also known as the "Merrill Lynch Rule".  Why the SEC wants
to turn back the pages by providing a special exemption, is beyond my
comprehension.  It can only serve the best interests of the industry, not
the consumer.  Please reconsider this Rule by revoking it, or at a minimum,
making it a level playing field, so that the consumer is not confused by
those who are bound by the rules of the Investment Advisor's Act, and those
who are not.  

Thank you for listening and hopefully for changing/revoking this Rule.  

Sincerely,

V. Raymond Ferrara, CFP
President and CEO
ProVise Management Group, LLC

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