Date:    05/16/2000  2:21 PM


File No. S7-25-99
     
Comment Against the proposal
     
Our firm is classified as a "small broker dealer."  It appears to me that 
rather than asking my brokers / registered representatives to sit for the 
Series 65 or Series 66 examinations that these proposed exemptions may in 
fact lower the standards.  For instance..
     
Broker Dealers are subject to less scrutiny of the investments they 
recommend:
When the wording of our wrap accounts specifically identifies that this is 
"just another way of pricing commissions" and it is not specifically related 
to the "market value of the account" then it would be left to the company's 
compliance department to be certain they follow standard marketing 
procedures.  We do not have a preferred list; our customers are and brokers 
are left to do their own research.
     
They do not have to disclose as much information on disciplinary action: 
When a broker/rr conducts his/her business under the name of the firm, the 
information that is on the CRD is less inclusive than the information that 
is on FORM ADV.  Is this really a good thing for the public?
     
They do not have to disclose conflicts of interest:
There seems to be a difference in the rules when it comes to "perceived 
conflicts of interest."  We are not a market making firm.  We have no IPO 
division and we do not release research reports.  An advisor has to disclose 
certain information and the advisor has to make an effort and substantiate 
an effort that he or she has found the "best market" for that order.  This 
portion of the proposed rule would seem to make it easier for us to move 
into the "wrap account" marketplace, without regard to the "best price for 
an execution."
     
They are not subject to the same competency requirements as advisors;
The firm is responsible for a continuing education -firm element- program, 
but I am not sure that attending a half-day seminar has the same lasting 
effect on the broker as the continuing education requirements or 
participation with examination results that are required for Investment 
Advisors or CFP's.  It appears to this writer that the demands for 
professional competency would be less under the "Certain Broker Dealers not 
to be an Investment Advisor" rule.
     
Who are "they?" at the beginning of each section.  "They" are broker dealers 
who would benefit a lot more than just "pricing" of a transaction service. 
We are they.  We would "benefit" by not having to meet a higher standard - 
all in the quest of better pricing.  It seems to me that there is an ethical 
conflict in some regulation - there should be a level playing field for all 
participants.  We all deal with the same "public"  Respectfully,
     
David L. Meckenstock, VP Principal, Main Street Securities, LLC, CFP, Hays, 
KS 67601