Date: Tue, 30 Mar 1999 11:35:42 -0700 From: "Gerard C. Coelsch" Subject: Response to file # S7-5-99 In response to the proposed amendments to Rule 15c2-11, the following is submitted: We have reviewed the proposed amendment to the aforementioned rule. While it is obviously intended to implement tighter controls and regulations in an effort to control fraud in the microcap markets, it becomes obvious that this particular amendment would in fact have the exact opposite effect by shifting responsibility away from the rightful regulatory agencies. By over burdening the market makers with the requirements proposed by this amendment, their priorities would be shifted so completely that they would no longer be able to do the job they are in the business to do. The liabilities thereby placed on them would be prohibitive to conducting business productively. They would, in fact, be responsible for information over which they have no control. We cannot imagine anyone taking on this obligation and responsibility under such circumstances. While we applaud the effort for more control and less opportunity for fraudulent activity, we sincerely believe that this particular effort would be catastrophic to that end.