From: Greg Cleary [gpcleary@callatg.com]
Sent: Tuesday, July 23, 2002 1:31 PM
To: rule-comments@sec.gov
Subject: File #S7-25-99

To Whom it May Concern,  I strongly disagree with the proposed SEC rule 
which allows certain broker dealers to be exempt from being registered as 
Investment Advisers.  As an investment professional who is registered under 
the Investment Advisers Act of 1940 I consider being an Independent RIA or 
Advisory Representative an important component in offering financial advice 
to consumers.  It seems obvious that certain broker-dealers are "spinning 
the issue" to create the perception that the investment advice being give 
is only ancillary to the transactions involved - all in an effort to avoid 
the costs of having their representatives registered.  I believe the extra 
costs today are far worth the benefits tomorrow.  The more education 
received by representatives the better the advice our clients receive.

Sincerely,


Greg P. Cleary, CLU, ChFC, CFS, REBC
Series 6, 7, 63, 65.