From: tgraffeo [tgraffeo@pacbell.net]
Sent: Monday, July 22, 2002 10:40 AM
To: Rule-comments@sec.gov
Subject: file no. S7-25-99

The Proposed rule is a bad idea for the financial profession-- especially at
a time like this.  Our (the USA's) economic future depends on more
credibility, not less.  We need more accountability, not less. (Look at
Japan and what has happened their because of banking and accounting)
Exempting some broker-dealers from the rules is like exempting Anderson from
GAAP rules, and then wondering why companies fail.  There are enough
problems with level rules, to make the field two tiered would certainly
confuse the consumer and be bad for our industry.

Two final thoughts:

1. Isn't the proposed exempt broker-dealer recently subject to a major fine
for not playing by the rules and mandated to apologize for misleading the
public.

2. Is this another example of thinking that certain broker-dealers are too
big to fail, so they'll do the right thing.  We have seen many examples
recently were nobody is to big to fail or be lured by profit potential.

This is not the time for a bill like this.  We need more safeguards for
clients, not more "trust me, we're big."

Tom Graffeo, CFP
949 766.1600
18 years of industry experience
voter