From: David Lazear [David@FinancialDesignsLtd.com]
Sent: Monday, July 15, 2002 1:28 PM
To: rule-comments@sec.gov
Subject: File S7-25-99, proposed rule, "Certain Broker-Dealers Deemed Not To Be Investment Advisors"


Dear Sir or Madam:

I write to object strenuously to the subject proposed rule.  In the best interests of the
investing public, I believe there should be a uniform, high standard for all who offer investment
advice, regardless of the type of business entity from which they operate.

I believe the SEC should have an overarching responsibility to try to give every investor the
fairest, most level, playing field possible.  If the fundamental rules of the game are carefully
thought through and uniformly applied, then the referee has an easier job.  He can spend more time
sitting in the stands and enjoying the game.

Please do the right thing here.  Do not favor "certain broker-dealers".  Do not favor anyone.

Thank you for your kind attention.

David A. Lazear
Financial Planner

Financial Designs, Ltd.
5075 Shoreham Place, Suite 230
San Diego, CA  92122-5964

Direct telephone:  858-625-9170
Fax:  858-546-1106
Email:  David@FinancialDesignsLtd.com

Securities through QA3 Financial Corp., Member NASD, SIPC

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