From: Ian L Randolph [mailto:ian.l.randolph@aexp.com]
Sent: Saturday, August 24, 2002 2:35 PM
To: rule-comments@sec.gov
Subject: File No. s7-25-99


As a financial advisor with a Series 24, 7, 65 I am opposed to the rule that "Certian Broker-
Dealers Deemed Not To Be Investment Advisers". I think all of them should be subject to the same
rules and regulations that i am.

Note: I will be sitting for the Series 53 next month and I am on my last CFP course. I also have a
degree in Finance.
_________________
Ian L. Randolph
Financial Advisor
American Express Financial Advisors Inc.
IDS Life Insurance Company
1375 W. Brierbrook Rd.
Germantown, TN. 38138-2208
Phone: (901)-312-5093
Fax: (901)-312-5084