From: Lance Fulk  
Sent: Monday, April 22, 2002 2:21 PM 
Subject: File No. S7-10-02 
 
I would like for your exemption of internet investment 
advisers to go beyond the "interactive" definition.   
  
I am starting up a new advisory business based on model 
portfolios, similar to the "interactive" type mentioned for 
the exemption.  However, I want to go beyond just telling 
them what the recommendation is, and also be able to offer 
to manage their account using that model.  In effect, I 
become their "discipline" needed to follow the investment 
approach. 
  
I want to offer my services on the web, nationwide, but 
since I am an upstart, I cannot afford to register with 
every state out there.  I also do not yet have $25 million 
under management.  I do not know how long it would take me 
to get to that benchmark either. 
  
I would not have an "interactive" service, and I would not 
have "personalized" service.  I would just simply present a 
choice of model portfolios, along with an explanation of how 
each is managed, and let the person choose.  I would then 
manage their portfolio according to the parameters for that 
particular model.   
  
Please take this into consideration and expand your 
exemption list to include smaller advisers that want to 
operate through the internet on a national basis, but do not 
have the required $25 million in assets under management.  
Thanks! 
  
Lance M. Fulk, CFP