From: Eric E. Haas [ehaas@altruistfa.com]
Sent: Tuesday, June 25, 2002 3:47 PM
To: rule-comments@sec.gov
Subject: Comments on Proposed Rule 202(a)(11)-1 under the Advisers Act:
File No. S7-25-99

Hello,

I have some comments on the proposed new rule 202(a)(11)-1 under the 
Advisers Act , "Certain Broker-Dealers Deemed Not To Be Investment Advisers."

My understanding is that the Investment Advisers Act was designed to 
protect the public when dealing with professionals giving investment 
advice.  Broker dealers have been giving sales pitches disguised as 
objective advice for some time, at the expense of their naive clients.

If anything, we need to provide further protections for consumers from the 
predatory practices of broker-dealers, not lesser protections.

Why should broker-dealers be allowed to give advice without the same 
restrictions as other investment advisers?  I believe that this makes it 
easier for them to pretend that their sales pitches are actually objective 
advice.

Let's follow the spirit of the Investment Advisers Act and provide 
protections for our citizens.  Also, let's not let the broker-dealers 
continue to get away with doling out their self-serving sales-pitches 
masquerading as investment advice.

I urge the SEC to protect its constituency, which are the citizens who need 
protection, NOT the broker-dealers who are looking for a free ticket to 
increase and expand their traditionally deceptive tactics.

All discretionary accounts of broker-dealers should definitely be treated 
as advisory accounts and be subject to the Investment Advisers Act.

Brokers should definitely be precluded from relying on the proposed 
exemption if they market accounts in such a way as to suggest they are 
advisory accounts.


I urge the SEC to withdraw proposed new rule 202(a)(11)-1 under the 
Advisers Act immediately.

Eric E. Haas
Altruist Financial Advisors LLC
3754 65th St
Holland, MI  49423-9739
616-857-2743