Date:    05/07/2000  11:04 AM

Subject: to jonathan katz, secretary, SEC

i am writing this in response to the proposed rule exempting broker dealers 
from investment advisory status.
     
1.  why would a broker dealer not want to adhere to investment advisor rules 
unless they are doing something contrary to the rules? broker dealers on the 
contrary should welcome any rules or frameowrk  within which to operate that 
gives them credibility and is perceived by the public to be a yet another way 
of ensuring compliance.
     
2.  there is a very fine line between "incidental advice" and actual advice. 
In this industry we should try and overcome these grey areas that are subject 
to interpretation. lets make it black or white.
     
3.  I have been associated with a couple of broker dealers in my career whose 
broker members have not been too ethical even without the investor advisory 
rules.
     
4.  with so many financial institutions presenting themselves to the public 
as  "investment specialists" , "financial specialist", "investment 
consultant" "financial consultant" etc there is no way  a lay person would 
know whether indeed the broker has any licenses or even comes under any 
jurisdiction or compliance rules.  please tell me the difference between the 
above 4 titles.  actually they are all brokers, some with very little 
training and are pure sales peopl on commission (another unethical way of 
compensation).  a few even do not give much thought to compliance or ethics 
so long as their "numbers are up". after all the only way they can support 
their families is to bring in an income, and their income depends on how much 
they sell, not how or to whom they sell.  their mode of payment is not at 
aqll compatible to working in the best interest of the clients.
     
actually i was once told "i dont care if it is the best interest of the 
client, you must do whatever it takes to get your numbers up".  This sort of 
approach would be eliminated if brokers had to have investment advisor status 
and work within a framework of rules.
     
 Do not even think of exempting them.  it is a very sore point with 
professionals who are ethical and compliant and who are true financial 
planners under supervision of a strict board of standards.  there is a big 
difference between a sales person and an advisor and brokers should be fully 
aware of this .
     
The financial services industry is already fraught with confusion and the 
general public has no idea how to start a complaint or present a negative 
comment.  perhaps the customer/client should be given a one page information 
sheet about how to send in acomment or complaint before any business is 
transacted.  
     
pleae dont exempt any broker from the investment advisory status.
     
rameela patel