From: Joseph G. Descant, III, CFP [jdescant@rjfs.com] Sent: Friday, June 21, 2002 1:51 PM To: rule-comments@sec.gov Subject: File No. S7-25-99 As a CFP and RIA for over 15 years, I have been held to a higher standard of ethics by the regulatory bodies, my clients and my peers and have embraced this with the utmost professionalism. I adhere to the code of ethics of the CFP Board and properly disclose my fees and any conflicts. I want to voice my opposition to the above referenced rule (Certain B/D's Deemed Not To Be Investment Advisors) and ask that you withdraw the rule. How can "Certain" people be exempt from registration. This undermines the very being of the financial planning profession. It allows unscrupulous "brokers" who have no training or education in financial planning to be exempt and therefore unaccountable for their actions and worse allows them to give bad and uninformed advice to the consumer. Again, I ask that you withdraw the rule. Thanks! Joseph G. Descant, III, CFP Certified Financial Planner Raymond James Financial Services