Subject: SEC Release 34-42099;IA-1845 Date: 07/05/2000 2:30 PM I am opposed to this proposed rule. The proposed rule hurts investors and the public for the following reasons: The rule will harm the SEC's image of championing investors Exempted broker-dealers can use client testimonials in advertising, whereas advisors are strictly prohibited from using them. Broker dealers would not have to disclose as much disciplinary or other information on the firm as advisors are required to disclose in Form ADV. Exempted BD representatives are not subject to the same state competency requirements as for those generally providing investment advice to the public on behalf of state and federally registered investment advisors. The rule will create an unfair advantage to the large brokerage firms, while not providing any benefit to the public. Exempted broker-dealers will have less liability because of the more stringent fiduciary duty under the 1940 Act. I reiterate my stand as strongly opposing this proposed rule. Sincerely, Eric Haudenschild