E-Mail 
 
February 9, 1997 
 
Jonathan G. Katz, Secretary 
Securities and Exchange Commission 
 
NEW INVESTMENT ADVISER EXEMPTION 
 
This section described a 90-day window if the adviser expected to have  
$25 million in "AUM." In my opinion 90 days to gain sufficient time to  
avoid the cost of reregistering. Our experience has been that it can take  
up to six months (and even longer) just to have a new client's assets  
transfered in from a brokerage company. Six months should be a minimum  
time frame. 
 
I am also concerned that a "new adviser" has 90 days to gain sufficient  
"AUM," but an existing adviser does not appear to have that same  
opportunity. For expample, my firm currently has approximately $18  
million "AUM" with the reasonable expectation that we will have $25  
million within 112 months. We have spent alot of money to be certain  
our administrative and marketing materials comply with our SEC  
registration. Now it appears that we will have to spend alot of  
money reregistering with our State only to change back within a year. 
 
Thank you for your consideration. 
 
Mike Miller, CFP 
President, South Carolian Chapter ICFP  
P.O.Box 5898 
Greenville, SC 29606