Subject: SEC Proposed Rule Excepting Certain Broker-Dealers from Inve

Date:    05/10/2000 7:29 AM
     
     
Honorable Arthur Levitt Jr. 
Chairman 
Securities and Exchange Commission 
550 Fifth Street, N.W. 
Washington, D.C. 
     
Re: File No. S7-25-99
     
Dear Sir,
     
I am writing to express my opposition to SEC Release Nos. 34-42099; IA-1845, 
"Certain Broker-Dealers Deemed Not To Be Investment Advisers." 
The public deserves full and fair disclosure and to exempt brokers from RIA type
disclosure would certainly not provide adequate information to an investor to 
make informed decisions when dealing with brokers.
To make investment advise "incidental" to brokerage sales under this proposal is
absurd based on the broker advertising and sales pitches to customers that they 
have superior investment advisors, financial consultants, analysts etc to help 
the client get better investment results.
Thank you for your consideration.
     
Robert Keats CFP
Phoenix, AZ