Date:    05/08/2000  11:18 AM

Subject: Re: File No. S7-25-99

Johnathan Katz, Secretary
     
Dear Sir, 
     
It has come to my attention that the SEC is considering an exemption for 
certain Broker Dealers from being registered under the 1940 advisor act when 
giving advice.  Nos.34-42099 IA1845.  I must tell you that after having been 
on both sides of the street, that being the commission world and the fee only 
world, that this may cause a lot more problems than benefits to the client. 
The natural conflict of interest that is present in the transaction world 
will not go away by exempting certain firms.  Things could get worse by not 
requiring additional education of the reps.  I know that every time I get 
more information in the form of education I can do a better job for my 
clients.  I think you should keep the playing field level and at the highest 
possible standards for the client.  Thank you for your consideration of my 
comments.
     
Sincerely,
     
Frank E. Jacober Jr.,ChFC
President
     
402 Harrison Court
Vernon Hills IL 60061
Jacober Investment Management, Inc.