Date:    4/15/97 3:04 PM
     
     
Jonathan G. Katz, Secretary
Securities and Exchange Commission
     
Dear Mr. Katz:
     
Regarding proposed Rule 17a-3(a)(16) requirement to update a client's 
financial situation and investment preferences annually, it seems that 
this requirement would be unduly burdensome for those accounts that have 
been inactive for a number of years because the "client" has elected to 
not transact business with the brokerage firm but retains, for example, a 
mutual fund holding or stock in client possession rather than street 
name.  
     
It would seem more appropriate that the "financial situation and 
investment preferences" update  be required before any NEW transactions 
would be allowed for the account of the client.
     
Steven J. Rumchik
Registered Representative/Principal
Cadaret, Grant & Company, Inc.
44700 Acacia Trail
Harris, MN 55032-3917
stevenrumchik@juno.com