SECFrom: Preston Caves [preston@cavesassociates.net]
Sent: Thursday, June 27, 2002 7:56 PM
To: rule-comments@sec.gov
Subject: Proposed Rule 

TO:     SEC

 

RE:      File No. S7-25-99

 

The headlines are replete recently with conflicts of interest in the 
brokerage industry and fraud in executive suites around the country.  
It does not seem like a good time to relax regulatory standards.

 

Meanwhile, the SEC proposed a rule to the Investment Advisers Act of 
1940 that permits certain broker-dealer activity an exemption from 
registration; and the SEC continues to leave this rule in a proposed 
status with no timeline for formal adoption.   Further, in my opinion 
the brokerage industry is not providing solely incidental advice and 
has taken a very liberal interpretation of the proposed rule in its 
aggressive advertising of financial planning services.

 

Therefore, I believe in the strongest possible terms that consumers 
and the public are best served by professional who provide financial 
planning advice acting in a fiduciary capacity, and who thoroughly 
disclose any financial and other conflicts of interest.  Thus, I urge 
the SEC to withdraw the proposed rule.

 

Preston S. Caves, CFA, MBA, CFP

Owner, Caves & Associates