Date:    05/08/2000  8:08 AM

Subject: SEC Release No. IA-1862; 34-42620. 

I am opposed to SEC Release No. IA-1862; 34-42620 for the following 
reason.
     
Broker Dealer representatives are subject to a less stringent customer 
'suitability' rule, and are not generally considered to have a fiduciary 
loyalty to the client as are registered investment advisers; the 
required "brokerage account" disclaimer will not be understood by the 
public and is completely inadequate. The public will be unduly 
influenced by the heavy marketing of the advisory services instead of 
the brokerage services and therefore assume that the services are 
advisory, not transaction oriented services.
     
Paul J. Toohey, CFP
Registered Principal
Registered Investment Advisor