August 22, 2000
     
     
Mr. Johathan G. Katz
Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.  20549-0609
Washington, D>C.  20549-060
     
\Re.:  SEC File No. S7-25-99
     
Dear Mr. Katc
     
This proposed rule is long overdue.  B/Ds have long had the requirement of 
complete and accurate disclosure.  A Series 7 Representative must pass a 
qualifying exam that covers vastly more than a Series 65 or 66.  Investment 
Advisors should not be so quick to declaim this rule.  After all, not one 
reputable B/D would let a Series 6 or 7 prepare for a public customer an 
investment plan that refers to a bond fund as a fixed-income product.  In fact, 
some of us are very concerned that certain financial planners and other advisers
are permitted to hold themselves out as such when, in reality, all they are 
doing is printing out a generic plan that comes from a boiler plate software 
program purchased from an entity that does not have be be registered with a 
regulatory authority.  A B/D that offers a non-discretionary fee-based option 
should pose no threat to the investing public or legitimate IAs.
     
Thank you for your time.
     
Sincerely,
     
Beth Schmidt
Vice President
Corporate Compliance Officer
Richard B. Vance & Company