Date: 04/12/2000 4:17 PM 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 The consumer of financial services is already very confused about who does what, charges what, has what conflicts, reports what and delivers what within the financial services industry. The proposal that would allow brokerage firms to avoid RIA registration under certain circumstances will serve to further confuse them and obscure the truth. It seems to me that consideration of two questions makes it very clear that these rules under consideration are not in the best interests of the consumer: (1.) Why do these firms want to escape RIA registration? (2.) How does this exemption from registration serve to further educate, enlighten or protect the consumer? Please understand that the independent financial advisors from whom you are hearing are not trying to create any unfair advantage for themselves. We are only interested in there being a level playing field and in the consumer's ability to make a well-informed decision about their choice of advisor. Consumers can not be expected to understand the difference between an SEC-regulated advisor and a non-SEC-regulated advisor, that with the former there are fiduciary standards to be met and with the latter no such standards, among other important but not readily visible differences. I'll ask the question again: Why do these brokers want to avoid this regulation? And why would the SEC want to support them in doing so? I am writing you on behalf of myself as an individual. But I think it is important for you to know that I am the current Co-Chair of The Financial Planning Association and past President of the Institute of Certified Financial Planners. I met with Mr. Levitt during 1999 and discussed financial services regulatory matters. He seemed very interested in and cognizant of the need for there to be regulatory parity among financial advisors. Please don't create further confusion on behalf of the consumer. We are making such good progress in educating the public about the benefits of financial advice and other general progress with financial literacy. This exemption from regulation will not add to that progress and may, in fact, detract from it. Elissa Buie, CFP Financial Planning Group, Inc. 510 N. Washington St., #300 Falls Church, VA 22046