From: Woodworth, Tracy [TAWOODWORTH@stoel.com]
Sent: Wednesday, July 18, 2001 6:38 PM
To: Rule-comments@SEC.gov
Cc: mfeinauer@zionsbank.com
Subject: File #S7-12-01

July 17, 2001



Jonathan G. Katz
Secretary
Securities and Exchange Commission
450 5th Street, NW
Washington, DC 20549-0106

Re:	SEC Bank Broker-Dealer Interim Final Rules
	(Release File No. S7-12-01)

Dear Mr. Katz:

I appreciate the opportunity to provide comments on the Interim Final
Rules ("Interim Rules") issued by the Securities and Exchange Commission
(the "Commission") regarding the "push-out" provision of the
Gramm-Leach-Bliley Act ("GLB Act"). Simply stated, I believe the
provisions of the Interim Rules create an environment that is extremely
"unfriendly" to my clients.

My professional relationship with Zions Bank dates back many years. If
the Interim Rules force trust activities out of Zions Bank and other
banks, my clients may be forced into fragmented relationships with their
chosen trustee and a third-party broker-dealer, and will be burdened
with additional costs that are entirely unnecessary. In addition,
because of the complexity and numerous non-statutory conditions imposed
on banks by the Interim Rules, banks will experience an increase in
their cost of doing business. The end result?  My client's costs as a
customer may well increase.

With the enactment of the GLB Act, Congress recognized that banks have
the expertise and customer relationships that make them uniquely
qualified to provide trust and fiduciary, custody and safekeeping,
asset-backed securities, and other specified traditional banking
products and services. Congress further recognized that banks have been
providing these products and services effectively for years by adopting
the exemption to permit banks to continue providing these traditional
customer services.

Ultimately, the real loser in the Interim Rules, as presently issued by
the Commission, are my clients, along with the other individual trust
customers. My longstanding bank relationship will be disrupted or even
discontinued, and my clients will end up paying more for the same
services the bank has provided for them for years. In the letter and
spirit of the GLB Act, and in the best interest of the individual trust
customer, I ask the Commission to immediately take the steps necessary
to bring the rules into accordance with the intent of Congress.

Thank you again for the opportunity to provide comments, and for
considering my comments.

Sincerely,


Richard H. Johnson, II
Stoel Rives LLP
201 So. Main, Suite 1100
Salt Lake City, Utah  84111
(801) 578-6941