Subject: File No. S7-25-99
Date:    12/28/1999 12:06 PM
     
     
As a registered investment adviser, I am very concerned that brokerage firms 
would be allowed to market their accounts implying that they give advice and 
yet not be requested to register under the 1940 Act.  Brokers should be 
precluded from relying on the rule if they market these accounts in such a 
way as to suggest they are advisory accounts.  
     
     
     Walter R. Greenfield