File No. S7-25-99From: Laurence Menna [LMENNA@RJFS.com]
Sent: Tuesday, July 16, 2002 3:39 PM
To: rule-comments@sec.gov
Subject: File No. S7-25-99

Dear SEC Chairman, 

I am writing to urge the SEC not to adopt the new rule "Certain Broker-Dealers 
Deemed Not To Be Investment Advisers."  File No. S7-25-99.  I do not think it 
makes sense, that any stockbroker can call themselves a "Financial Planner" 
without having a background in Financial Planning.  I know a lot of stockbrokers, 
and I don't hang-out with any of them.  You see, to them, the most important 
thing they want to talk about is how much they made on the last sale, month, 
or whatever.

Consumers need proper education and advice.  I hold myself out to the public 
as a "Financial Planner" because I truly have the tools, experience, educational 
background, and the drive to make sure we help our clients in the most 
productive way as possible.  Every decision we help our clients make is based 
on their situation.  You know what I talk about?  How we made a difference 
with this client or that client (we don't use their names of course).  

The background requirements, to be good at Financial Planning, are so extensive, 
that not many "Stockbrokers" are going to be willing to take the time to understand 
them, nor understand their clients.  I have built my practice, very slowly, 
concentrating on my clients--not the growth of my business.  I am currently 
studying for the CFP exam, and will move on to the CFA afterwards.  I am in the 
process of changing my practice to a "Registered Investment Advisor" because we 
want to get as far away from the commission sales business as possible.  I never 
liked it, and I have chosen to base my practice on fees.  We want to get paid 
for our advice, not our salesmanship.

Please withdraw the proposed rule. 

Sincerely, 

Laurence E Menna 
Financial Planner / Branch Manager 
Raymond James Financial Services, Inc. 
Member NASD/SIPC 

www.raymondjames.com/bakersfield 

*Office:  661-837-8500 
*Cellular:  661-978-6700 
*Fax:  661-837-8926 
*e-mail:  lmenna@rjfs.com 

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