From: E J Buerckholtz [EJB2@ntrs.com]
Sent: Thursday, June 27, 2002 4:35 PM
To: rule-comments@sec.gov
Subject: File No. S7-25-99

To:    SEC Rule Comments
RE:    File No. S7-25-99
From:  Elizabeth J Buerckholtz, Illinois


I am a CFP and a series 7 holder and am very concerned about the proposed
SEC rule, "Certain Broker-Dealers Deemed Not To Be Investment Advisers."

Please withdraw this proposed rule.

It does not provide for fiduciary standards by brokers nor does it require
disclosure to clients by brokers of conflicts of interest.  Broker-Dealers
should not be exempt from registration under the Investment Advisers Act of
1940 and the associated disclosure and fiduciary standards.  I believe that
would present ethical problems which, at all costs, should be avoided.

Thank you for the consideration.