Author:  "Stephen Wack" 
Date:    05/13/2000  6:01 AM

Subject: S7-25-99

No to the proposed rule change.
     
Whether a representative is salaried, commission based, or fee based is 
irrelevant. I have been all three. What is relevant is the quality of 
information given to account holders. I was a salaried brokerage transaction 
only representative for 9 months. Account holders called asking questions 
that require substantial training and sophisticated securities' knowledge. 
Some days I would take over 100 calls. (Many were internet traders.) Account 
holders frequently asked questions regarding, options and complicated 
spreads, margins, bonds, yields and stock fundamental and technical 
performance. Basic questions concerning the difference between a market, 
limit, stop, stop limit were common. The average brokerage investor knows 
little about investing basics. making an exception to the Investment 
Advisor's Act of 1940, will allow untrained, unskilled representatives to 
answer questions (from people that do not have a clue) with answers that are 
poor quality, incomplete or inaccurate. The proposed rule lessens investor 
protections so that brokerage houses may save a few dollars after having to 
lower extremely high commissions after competition arrived in the 
marketplace.