From: Power Plans [powerpl@gte.net] Sent: Tuesday, June 25, 2002 3:29 PM To: rule-comments@sec.gov Subject: File No. S7-25-99 Gentlemen: I write today to voice my objection to and request immediate withdrawal of the proposed SEC Rule “Certain Broker-Dealers Deemed Not To Be Investment Advisors”. This proposed rule passes no test of reason. All broker-dealers are, by their very nature, investment advisors. They MUST be treated and regulated as such. There is a whole industry of financial planners, many of whom place the client’s interest foremost, that are subject to such regulations. Why would anyone seriously consider exempting broker-dealers and their representatives from similar scrutiny? It would appear that there is industry pressure to promote such an exemption. The argument most likely is that the broker-dealer is already regulated in many ways, and registration as an investment advisor is an unnecessary add-on. My response is that the other forms of regulation have to do with the mechanics of the broker business and not the advice rendered to clients. This regulation is crucial to the protection of the investing public. I have been a CFP for eight years and subject to a Massachusetts Department of Securities audit. I know the value of audit, and the utility of the process as one that adds discipline to the practitioner and value to the public. Public confidence in the equity markets and associated industries is essential for the strong American economy to continue. Any diminution of the confidence is a mistake. To remove certain broker-dealers from oversight would be such a mistake. I strongly urge you to withdraw the proposed rule. John R. (Dick) Power, CFP Power Plans 17 Pheasant Hill Road Walpole, MA 02081-2221 Telephone: (508) 660-9770 mailto:power.plans@gte.net