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To: The Duke of URL© who wrote (111133)	9/24/2000 3:22:51 PM
From: CountofMoneyCristo	Respond to of 186894

Duke! YES. This has been my main point from the very beginning. Now why are not all of these sites required to register with SEC? The problem lies in this language, which gives SEC room to maneuver: Investment Adviser's Act of 1940, Title 15, Chapter 2D, Subchapter II, Sec. 80b-3a(c) - Exemptions. - (c) Exemptions Notwithstanding subsection (a) of this section, the Commission, by rule or regulation upon its own motion, or by order upon application, may permit the registration with the Commission of any person or class of persons to which the application of subsection (a) of this section would be unfair, a burden on interstate commerce, or otherwise inconsistent with the purposes of this section. Now I have argued this critical point with the Commission, and others, time and again, but it appears that a Supreme Court ruling, United States vs. Lowe, made it very difficult to nail down non-establishment concerns as falling under the legal definition of IA's. I expect this will change in the near future. Sincerely, Olivier L. F. Asser Founder and CEO, Stock Operators, LLC, stock-operators.com