March 12, 2003

TO: Files
FROM: Daphne Tippens Chisolm
Counsel to Commissioner Goldschmid
RE: Release Nos. 34-42099; IA-1845; File No. S7-25-99

On October 3, 2002, representatives of the Consumer Federation of America, Consumers Union, Common Cause and U.S. Public Interest Research Group met with Commissioner Campos, Heather Traeger (counsel to Commissioner Campos), Commissioner Goldschmid and Daphne Chisolm (counsel to Commissioner Goldschmid). One of the topics of conversation concerned the Commission's rule proposal to exclude certain broker-dealers from the definition of investment adviser. CFA representatives (including Barbara Roper who acted as the CFA spokesperson on this issue) expressed the views contained in their firm's comment letter (see Commission File No. S7-25-99).