Date:    05/17/2000  12:29 PM

Subject: File Number S7-25-99: Proposed Rule Exempting Certain Broker
 
I am writing in opposition to SEC Release Numbers 34-42099 and IA-1845 
(Certain Broker-Dealers Deemed Not To Be Investment Advisers).  I believe 
that the proposed Rule is harmful to investors, the investment advisory 
community, and ultimately to the public's image and perception of the SEC 
as an organization protecting the public interest.
     
As the SEC is undoubtedly aware, the distinctions between the fee-based 
investment advisory community and the broker-dealer ("BD") community are 
becoming increasingly blurred.  Increasingly, BD firms are encouraging 
their "financial advisors" to add value by providing advice in a variety of 
investment and non-investment areas, and to move their business towards 
generating recurring revenues--especially through the use of asset-based 
"wrap fee" accounts, in which there is less of a conflict of interest with 
the client or customer.
     
Being associated with an independent Registered Investment Advisory firm 
myself for many years, while also holding my General Securities license and 
my General Securities Principal license, I can tell you that the scope of 
advice being now promulgated by the BD firms and their representatives is 
similar to the scope of advice I have been offering clients for years.  To 
exclude them from registration under the Investment Advisors Act is a 
"distinction without a difference" and creates an uneven playing field in 
the financial community and confusion in the minds of the consumer.
     
Under the proposed rule, consumers will not have access to the same 
information for BD related advisors as the SEC itself deems important for 
other Registered Investment Advisors--information contained in the new Form 
ADV.  BD representatives will not be subject to the same "suitability" 
standards, and they will not generally be considered to have a fiduciary 
loyalty to their clients. 
     
I join the Consumer Federation of America and the AARP in urging the SEC 
not to adopt this rule.
     
Daniel H. Boyce, CFP, CIMC
Center for Financial Planning, Inc.  Registered Investment Advisor 
26211 Central Park Blvd, Suite 604, Southfield, MI  48076