Subject: File # S7-10-99
Author:  <tom_rice_at_rice-headoffice@ricemail.ricefinancial.com>
Date:    5/19/99 4:35 PM
     
     
     
     Please be advised that our firm, Rice Financial Group Inc., is a 
     current member in good standing with the Investment Funds Institute of 
     Canada (IFIC).
     
     We are generally supportive of the proposed rules under consideration.
     
     Our firm understands that IFIC wil be submitting a detailed commentary 
     on the proposed rules, and we are supportive of their comments.  Our 
     firm further believes that the proposed rules are necessary, and that 
     quick implementation is important.
     
     In addition to the proposed rules, there needs to be relief for 
     dealers who act in connection with trades in securities held in 
     Canadian retirement accounts beyond their current abilities to act.  
     In particular, as Canadian dealers and their authorised 
     representatives are often situational fiduciaries of clients,  
     Canadian dealers require the ability to contact clients in the US in 
     situations where their fiduciary obligations require such a contact.  
     
     The current requirement that written acknowledgement to be obtained 
     from Participants as to the non applicability of US law is too 
     difficult and costly to administer, so many firms that would otherwise 
     sell to Participants under the proposed exemption would elect not to 
     do so, and thereby limit the Participant's investment options.
     
     We therefore request that your consideration be quickly given, in 
     order that Canadians who are out of the country may be serviced in a 
     manner which is in the clients best interest.
     
     If you have any questions or comments on the above, please do not 
     hesitate to contact me.
     
     Thomas J. Rice, CLU
     President & Chief Executive Officer
     Rice Financial Group Inc.
     491 Portage Avenue, Winnipeg, Manitoba R3B 2E4 Canada