Subject: File number: s7-19-99 Author: "Jacquelyn Garcia" at Internet Date: 11/1/99 1:07 PM November 1, 1999 Mr. Jonathan G. Katz, Sec. Securities Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549-0609 Subject: File No. S7-19-99 Dear Mr. Katz: On behalf of Florida International University's Business and Society class, Miami Fl, we agree with the actions that are being proposed within this rule and rule amendment. This conclusion was drawn up with the help of the evaluation of the supplementary information provided as well as extensive research via wold wide web and Miami-Dade and Broward County libraries. Even before our research, we were shocked that the "Pay to Play" practices were still in occurrence. It is in our opinion that these practices are completely unethical, highly unjust, unfair and should not be tolerated by the people and certainly not from the Commission. In today's world where morality and integrity are placed far behind from personal advancements, We believe that rules such as these are becoming requirements to ensure some sort of equality or fairness within all business types more so seeing that these actions are taking place within our government agencies. From the beginning of our government "Checks and Balances" have always been placed so that to ensure the distribution of power. We see this proposed rule as a sort of "Checks and Balances" on the officials who have the power of awarding advisory contracts. The elected officials who allow political contributions to play a role in the management of these assets violate the public trust. This "Pay to Play" practice distorts the selection process by rewarding those who make political contributions. These actions are an infringement on all our rights, a fair process should be used and the most qualified should be awarded. Unfortunately the ideal situations are usually those which are also the most difficult to achieve. That is why an alternative such as this one is needed. The proposed rule's actions to prohibit an adviser from providing services for compensation to any government client for two years after their contribution is made and its actions to prevent advisors to provide services if they solicit contributions for an official will assist in encouraging the right type of atmosphere and the right attitude towards the serious nature of the government official's duties. The control over these actions will allow the most qualified advisers to be sought out and selected. Previous reports of these actions have been found in over seventeen states already and some states have even begun to create their own statues or laws to regulate these actions. A rule at the federal level though, will enable a standardized process to which all must obey. Such a set of standards will also help prevent these actions from even beginning in other parts of the nation and rather become a sort of prevention mechanism for them. This process has already been proven effective in other rules that regulate a similar situation (Pay to Play) but rather in other positions. In regards to the assumption of limiting the effectiveness of this rule to simply cover those advisers registered with the commission, we disagree. By allowing this gap within the rule you are encouraging those who do practice the "Pay to Play" actions to use this gap for their own benefits. If this law is to prevent fraudulent and deceptive actions why limit it to the areas where the problem seems the most concentrated. Expanding it to cover even the smaller sectors such as those state registered advisers will make this rule a stronger, more effective one. And by expanding this rule to cover thoroughly, you are making it more difficult for those who do practice to find a way around the legalities of this rule. We hope that our opinions and insight into this issue will assist in your decision making. Sincerely, FIU Business and Society Students Jacquelyn Garcia Cynthia Springstun Brett Screpe