Date:    05/21/2000  7:12 PM

Subject: Re: File No. S7-25-99

May 21, 2000
     
     
Jonathan Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C. 20549-0609
     
     
Dear Secretary Katz,
     
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 proposed rule will be harmful to investors in that it will very 
effectively serve to blur the distinction between per se and solely 
incidental investment advice -- the very distinction the 1940 Act attempts to 
draw.
     
True and distinct functional regulation requiring clear and express 
disclosure will best serve the interests of all parties, including investors, 
regulators and service providers.
     
While I urge you to reconsider this very troublesome rule, as a professional 
financial planner I very much support the Commission's overall investor 
protection mission.
     
Respectfully,
     
Guy M. Cumbie, CFP
     
     
CUMBIE ADVISORY SERVICES
442 Fort Worth Club Building
306 West 7th Street
Fort Worth, TX 76102-4905