Subject: Regarding File No. S7-10-00

Date:    05/31/2000 7:26 PM
     
     
Many of the proposed changes to the ADV filing are good ones.  There *should* 
be additional disclosure about fees charged and about the individuals 
involved in management of clients funds.
     
However, this should be done as a *level playing field*.  Mutual funds for 
example, are exempt from many of these requirements.  They do no have to send 
a client an itemized bill for services on a quarterly basis.  In fact even 
loads as high as 5.5% are hidden from clients when purchasing mutual funds. 
They only have to disclose a percentage to the client in an unreadable 
prospectus, but never the specific dollar amounts.  Mutual funds also do not 
send an ADV equivalent every time there is a change that would make a 
prospectus 'materially inaccurate' (i.e. the change of a fund manager), or 
when 'style drift' sets in.
     
Instead of just broadening the ADV, I would recommend broadening even more to 
a single universal disclosure document for all brokers, advisors, mutual 
funds, limited partnerships and hedge funds, that would disclose all of the 
information being proposed for the new ADV.  If advisors must disclose soft 
dollar arrangements then why don't brokers have to disclose payment for order 
flow and 12b-1 charges being captured?  Why don't mutual funds have to send 
an invoice with at least an estimate of the quaterly fees debited as advisors 
are required to do?
     
If the SEC is truly trying to protect the consumer, and not just the powerful 
brokerage   and mutual fund industries, I believe that nothing else makes 
sense.
     
Sincerely,
     
Donald Steinmann
Advanced Financial Management
225 S. Lake Ave. #300
Pasadena CA 91101