To: SEC

From: Dale A. Pope

Date: June 24, 2002

RE: File No. S7-25-99

I have the following comments regarding the SEC's proposed rule exempting certain Broker-Dealer (BD) activity from the Investment Advisers Act of 1940.

You are correct in permitting certain BD activity an exemption from registration. BD investment advice is solely incidental to the sales and consulting process. Investment advisory activity for a fee is different from providing investment information to a client in order for a client to make an informed decision.

I hope you stay with your position and oppose the FPA's position.

Thank you.

Dale A. Pope
22 year member of FPA
Broker-Dealer executive