From: rguerra@frostbank.com Sent: Wednesday, June 26, 2002 10:35 AM To: rule-comments@sec.gov Subject: File No. S7-25-99 I strongly urge you to withdraw the proposed SEC rule " Certain Broker-Dealers Not To Be Investment Advisers." Instead of increasing the protection of consumers this rule gives the perception of the SEC weakening the protections consumers need more now than ever. The corporate scandals, insider trading, accounting irregularities, conflict of interest research analyst , etc. all point to a need for standardizing the Code of Ethics and Standards of Professional Responsibility. This proposed SEC rule harms rather than protects consumers during this period of intense public scrutiny of our securities industry. Please hold all security dealers/representatives to the highest standards, don't lower the bar for a select group that probably needs them more now than ever to protect the public and themselves. Rick T. Guerra, CFP Vice President, Frost National Bank