From: Bob Kerstein [bob@scripophily.com]
Sent: Sunday, March 04, 2001 12:38 PM
To: rule-comments@sec.gov
Subject: Re: S7-18-00

Mr. Jonathan G. Katz
Secretary
Securities Exchange Commission
450 Fifth Street, North West
Washington, D.C. 20549-0609
Re: Comments Regarding File No. S7-18-00


Dear Secretary Katz:

The Commission of the Securities and Exchange has requested comment on the 
addition of proposed rule 240.17Ad-19, and amendments to rules 240.17f-1 
and 240.17Ad-12.  As a Certified Public Accountant and owner of 
Scripophily.com, I can appreciate the balance that must be maintained 
between historical preservation and fraud prevention.

The collection of stock and bond certificates issued from companies and 
governments is an important and growing hobby.  Looking at these old 
certificates, you can find out information that isn't available in 
textbooks or other resources.  These certificates provide historical 
fingerprints of how company's were financed and operated.  The beauty of 
the designs, officers names and autographs, company types and names, 
successful and unsuccessful businesses, scams, methods of cancellations, 
transfers and endorsements, all add to the history.  It would be a shame to 
lose of this information for future generations.

On the other hand, I don't believe company's or transfer agents should be 
required to keep all of these certificates in storage beyond a reasonable 
period of time.  In this day and age, electronic copies should be able to 
do the job as has been done with checks for many years. Ultimately, it 
should be the company's decision as to what to do with their property.  As 
a collector I hope the history is preserved, but as a businessman I realize 
the storage can be very expensive.

I believe the answer lies in the cancellation techniques and the availably 
of information on the internet regarding company histories and status.  I 
personally feel the current cancellation techniques are adequate, but I am 
not as close to the problem as the S.E.C.  You are in the best position to 
address this problem.  As far as the availability of company information, I 
believe a lot could be done.  Our company started a service called Research 
Old Stocks (researcholdstocks.com) because to the many inquiries we were 
receiving.  The more time I spend in this area, the more I see the 
necessity for a centralized database of information.  Each state have 
different ways to investigate  the statue of companies.  Some of their 
records and retrieval methods are excellent, others are very poor.  Some of 
the states charge for this service, others do it for free.      The 
availability of reliable information to everyone would help prevent frauds 
as well as provide a tremendous public service.

Should you have any questions or like any additional information, please 
fell free to call me at 703-787-3552.


Sincerely,


Robert A. Kerstein
President, Scripophily.com