From: Gallaher, Austin [Gallaher.Austin@pmlmail.com]
Sent: Tuesday, June 25, 2002 1:32 PM
To: rule-comments@sec.gov
Subject: File No. S7-25-99

To Whom It May Concern:

I strongly urge the SEC to reject the proposed rule concerning "Certain 
Broker-Dealers Deemed Not To Be Investment Advisors." The logic of carving 
out an exemption for "certain broker dealers" is both absurd and misleading. 
Consumers of financial services have a right to expect clear, consistent 
rulings that are in the best interests of the public; the proposed rule 
only serves to muddy the waters and increase consumer cynicism.

Austin Gallaher, PFP
Financial Plan Development & Design
Comprehensive Financial Group
San Diego, CA
(858) 202-7262