Subject: Objection to exempting broker/dealers from ADV registration Date: 04/13/2000 11:30 AM Mr. Jonathan G. Katz Secretary Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549-0609 Re: Release Nos. 34-42099 and IA-1845; File No. S7-25-99; Certain Broker Dealers Deemed Not To Be Investment Advisers Dear Secretary: As a fee-only advisor and a member of NAPFA, an organization that takes full disclosure and their fiduciary responsibility to clients very seriously, I oppose the exemption from SEC registration you are proposing for broker dealers. You are encouraging an even greater unfair playing field on a field where players are not playing the same game. Why should we, who take a fiduciary oath to act in the best interests of our clients and who take the most objective and comprehensive approach with clients operating on a fee-only basis, be regulated and those who are not so objective be exempted from this rule? It makes no sense. You are encouraging further obscurity rather than clarity in advice provided to the consumer of financial services. We are not just interested in protecting our turf as fee-only advisors, but we are a voice for the consumer of financial services who deserve full disclosure at all times. This may be the easier path to take but it is not the best. If you are operating in the best interests of the public, you would be doing something about regulating these operators who are under the "protection" of another governing body. They'll use this lack of regulation to their competitive advantage and it will not be good for the consumer. What advocacy do you work for? A response would be greatly appreciated. Nancy Bryant, MBA, CFP Member of NAPFA