Subject: File No. S7-25-99
From: Raymond H Gambel
Affiliation: Retired

February 16, 2005

I believe the comment period for this extraordinary proposal should be extended to April 1 in honor of the fool who proposed it and the fools who support it. The SEC has already sown the seeds of confusion with its splitting of registrations between states and themselves and now proposes to confuse the confusion. Moreover, one would have to be Rip Van Winkle to be impressed with the SECs diligence and dedication in pursuing investment advisors in the last decade or so.

I believe that advisors take on additional burdens of diligence, competency and care that will be eroded if every person who passed a series 6 or had an impostor pass it for them, were given a misleading title implying more competence than their cram course likely empowered them to offer.

If increase in the confidence the public has in their Representatives is the goal, why doesnt the Commission call them Genius Clairvoyant not Medium, as that implies they will only meet average performance or some other title endorsing the concept that those who sometimes write unsolicited order and sometimes hopefully, rarely suggest products for som undisclosed remuneration in kind.

I believe that, if the SEC wants the power thay should demonstrate the persistence in regulating the advisors, broker-dealers agents, SROs and Exchanges that are already subject to the SECs lackadasical and uninspired regulation of those entities within its current purview.

Then, perhaps when the cynics have become converts and the converts have become acolytes, we can revisit the issue.

NOTE: system does not seem to accept all punctuation