Date:    05/03/2000 9:01 AM
     
     
Mr. Jonathan G. Katz
Secretary
Securities and Exchange Commission 450 Fifth Street, N.W. 
Washington, D.C.  20549-0609
Re:     Release Nos. 34-42099 and IA-1845; File No.S7-25-99; Certain Broker 
Dealers Deemed Not To Be Investment Advisers
Dear Mr. Katz:
I am writing you to comment on the proposal to exempt brokerage firms from 
registering as registered investment advisory firms under certain 
circumstances. As an independent financial advisory firm, we must educate the 
public about how the current regulatory framework is meant to protect them and 
where it falls short.  Most clients have the perception that their financial 
advisor always acts in their best interest.  This perception is built and 
encouraged by individual advisors as well as the large financial services 
companies. Very few clients understand that the Registered Investment Advisory 
regulations are the only ones which require advisors to act as a fiduciary for 
their clients.  If the SEC allows large financial services firms to avoid 
having to follow the RIA regulations, yet allow them to present themselves as 
objective fee advisors, then the general public will be misled.
Only if the SEC reserves for itself the authority to crack down on advisors 
and companies who present themselves as objective advisors, but then do not 
act as fiduciaries, will the general public be protected.  Thank you for 
your attention.
                                Sincerely,
     
                                Charles D. Haines, Jr.