Richard K. Schroeder, CFP
1325 Millersport Highway, Suite 208
Williamsville, NY  14221
716-634-6113
     
6/5/00
     
Dear Sir or Madam:
     
I would like to make some brief comments on the rules proposed in 
Release No. IA-1862.
     
I applaud the Commission for helping consumers and registered investment 
advisers move into the modern Internet age. I believe putting ADV 
materials on the Internet for all to see will greatly benefit consumers. 
All too often I see prospective clients who are surprised to be handed 
my New York State ADV, because they had interviewed other investment 
advisers and received no disclosures.
     
I find one portion of the proposal troubling. That is the proposal that 
annual ADV filings be mailed to all clients, and that interim changes in 
the ADV are also cause for a mass mailing to clients. I believe this 
will be a burdensome rule for several reasons:
     
1. The time and cost of mass mailings of heavy documents are a 
burdensome cost to  businesses.
2. I don't believe existing clients want the extra paperwork. I have had 
only three requests for updated ADVs from clients in my six years in 
business. Many clients ask me how to cut down on paperwork. They tell me 
they throw out updated prospectuses, annual mutual fund reports, and 
corporate reports without reading them. I spend a lot of time 
encouraging them to read complicated paperwork.
3. In an Internet age, why should we add the new environmental cost of 
duplicating thousands of pages of material?
     
Is it possible to amend this rule to allow transmission of the updated 
prospectus via e-mail and/or postings on adviser's web sites? It seems 
to make sense to allow electronic transmission given that the overall 
tenor of the Commission's proposal is to make better use of the new 
electronic means of communication open to consumers and advisers.
     
Thank you for your attention.
     
Richard Schroeder, CFP