Date:    06/05/2000  11:17 AM

Subject: File No. S7-10-00; Comments

Dear Securities and Exchange Commission,
     
II. DISCUSSION
     
A. The Investment Adviser Registration Depository 
2. The Public Disclosure System
     
All current information submitted to the IARD by advisers will be available 
to members of the public through our web site without charge.26
     
How do you propose to keep the financial service marketers from using your 
 Investment Adviser Registration Depository (IARD) system to inundate our 
e-mail and faxes with unsolicited offers?  From attending the investment 
advisor conferences where the mailing list is sold, I receive much more 
mail than I want.  Frequently at those conferences I don't have to supply 
my e-mail or fax numbers which limits the burden on my systems.  I don't 
want to imagine what the response could be from your free system.  If you 
could make the e-mail address and fax number private and only available for 
your regulatory purposes that would be appreciated. I also don't want to 
give the impression that I am advertising through either of these by making 
them available to the public.
     
4. Filing Fees
     
The Advisers Act permits the operator of the IARD to charge reasonable fees 
to cover system costs.33 We will pay NASDR to build the system; filing fees 
will be used to pay for its operation and maintenance. NASDR will charge 
fees for initial applications and annual updating amendments.34
     
I understand paying to meet my filling requirements, but not for operation 
of a public information system.  If it is for the good of the general 
public then the general public should pay for it.
     
We expect IARD annual filing fees to range from $200 for smaller advisers 
to $400 for the largest advisers.
     
I am a state registered advisor paying $125 annually to the state and 
nothing to the SEC.  An added $200 is way too big an increase.
     
D. Proposed Revisions to Form ADV,2. Part 2,a. Part 2A: The Firm Brochure 
To allow advisers to make a smooth transition, we are proposing a further 
30-day transition period to allow advisers to provide the new brochures and 
supplements to existing advisory clients.115
     
I don't meet with all my clients that frequently.  In some cases their 
schedules don't permit it.  I realize that I could just mail it to them but 
when I want my clients to understand something I discuss it with them. 
 When it is really important, like I suspect you want these changes to be, 
I like to discuss it face-to-face.  90 to 120 days would be more convenient 
for my clients.
     
Thank you for the opportunity to respond.
     
Regards,
     
Dean Lycas