Subject: File S7-10-00  Electronic filing by investment advisers

Date:    06/01/2000 9:11 AM
     
     
I am a State registered, fee only adviser -  a one person sole proprietorship.
     
I have the following comments:
     
1. I believe the electronic filing proposal is a sound idea that will facilitate
comparison shopping for advisers by the investing public. I fully support the 
overall concept of the proposal. 
     
2. To facilitate browsing and comparison shopping by the public, the format for 
the disclosures - including the brochure -  should have some standardization. 
The level of standardization required by the current "check the box" format for 
parts I and II is not required, but care should be taken to retain enough format
comparability to make browsing and comparisons between advisers a relatively 
easy task for the public.
     
3. My biggest concern is the proposed fee structure.  As proposed, the smallest 
advisers will pay $200 and the largest will pay $400.  This is a tremendous deal
for the large advisers, but not equitable for the smallest advisers.  Fees 
should bear some resemblance to system maintenance costs.  Compare system 
maintenance costs for a one person firm such as my own and a firm with hundreds 
of advisers and associates.  System maintenance costs for the larger firm will 
obviously be more than double the amount for the smallest adviser firm.  It 
looks like a cross-subsidy of the larger operations by the smaller companies to 
me.
     
My concern is not about being able to pay a $200 fee, but about the apparent 
unfair cost treatment given to the larger firms.  The larger firms may well save
money over the current system, but this will not be the case for the smaller 
firms.  The state filing fees, administrative costs, and notary fees for the 
smallest firms currently are less than $200 annually. The current fee proposal 
will increase regulatory costs for small firms while saving costs for the larger
firms.     
     
Michael James Skinner  -- A California Registered Adviser