Date: 05/06/2000 2:22 PM Subject: File No. S7-25-99 I am writing to express my opposition to SEC Release Nos. 34-42099; IA-1845, "Certain Broker-Dealers Deemed Not to be Investment Advisers>" The effect of the rule will be to encourage brokers to continue practices of pretending to do financial planning without the disclosures required of financial planners. Currently, brokers are calling themselves financial consultants and offering products to the public as "no-load" when in fact they are presenting fully loaded products . The effect of the above referenced rule will be to encourage this and similar activities. In fact, the rule comes at a time when financial planners are being required to provide more extensive disclosure and its runs counter to the express needs of the public. I urge you not to put this ill-conceived rule into effect. A. Raymond Benton, CFP