From: Jfinvest@aol.com
Sent: Tuesday, June 25, 2002 5:39 AM
To: rule-comments@sec.gov
Subject: Re: SEC File No. S7-25-99

June 24, 2002

Honorable Harvey Pitt
Chairman 
Securities and Exchange Commission 
Washington, D.C. 
 
Dear Chairman Pitt,

I am writing to express my opposition to SEC File No. S7-25-99, "Certain 
Broker-Dealers Deemed Not To Be Investment Advisers." 

Is the wire house lobby that entrenched in our political system whereby it 
can erect a wall around the way it does business unnoticed by the 
unsuspecting investing public and unregulated by our industry? How can the 
investing public expect a level playing field if there are privileged 
segments in our industry not being held up to the same standards of scrutiny 
when the same service is provided?

Regulatory supervision is a time and labor intensive effort. Let us hope the 
proposed Rule allowing broker-dealers to offer comprehensive financial 
planning advice without being subject to registration under the Investment 
Advisors Act of 1940 or similar state laws is a result of the regulatory 
agency's limited man power or time constraints.

Or perhaps you are suggesting that by virtue of the title ' Broker-dealer 
representative' - they should be subject to less stringent customer 
suitability rules, and therefore not considered to have a fiduciary loyalty 
to the client as are Certified Financial Planners. Why? Are you suggesting 
the BD representatives are more prepared? more competent? more trustworthy? 
unable to bear the cost of compliance? shouldn't be exposed to the same 
liability as the rest of the industry?

The BD representatives are not subject to adhere to similar standards of 
conduct based on the CFP Code of Ethics and Professional Responsibility as 
required for those providing financial planning advice to the public under 
uniform standards of conduct. This inequitable proposal would peel away yet 
another layer of investor protection at the expense of the investing public, 
and most regrettably our industry. 

I urge to please consider withdrawing the proposed rule.Thank you for your 
attention.

Sincerely,
Jeanette Fierstein, CFP
Westborough, MA
508.366.4900
 
 
 
 
 
 


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