From: Wm. Stan Bivin [sbivin@bivinandassociates.com] Sent: Monday, June 24, 2002 12:45 PM To: rule-comments@sec.gov Cc: Don Nickles Subject: File No. S7-25-99 Gentlemen: I am writing to second a recent resolution of the Financial Planning Association opposing the SEC proposed rule exempting certain broker-dealer activity from the Investment Advisers Act of 1940. If brokers provide investment advice and financial planning, they should be held to the highest standards required of all Registered Investment Advisers, and be required to make full disclosure of any conflicts of interest. The commission should abandon this proposed rule, in light of the investor's already hightened concern, infavor of the existing standard that requires advisers to act always in the best interest of their clients. Wm Stan Bivin, CFP Bivin & Associates, Inc sbivin@bivinandassociates.com