Date:    05/08/2000  7:52 AM

Subject: Re: File No. S7-25-99

Jonathan Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609.
     
As an existing financial Planner (CFP), Investment Adviser (RIA) and Registered 
Representative (Series 7, 24, 63) I would like to voice my opposition to the 
proposed rule.  It is a bad idea to add complexity by creating more levels of 
expertise.  It will also hurt the investing public by allowing a lower standard 
for what amounts to investment advisory when what really is being done is 
brokerage (transaction based activity).  While this rule could potential make my
regulatory life easier (I could give up my RIA and still be able to give 
investment advice), I no long term benefit to the general investing public nor 
the professional status of the financial services industry.  I urge you to 
please reconsider and end this rule now.
     
Respectfully,
James L. Losey Jr., CFP, CLU