May 10, 1999

Jonathan G. Katz, Secretary

Securities and Exchange Commission

450 5th Street, NW, Mail Stop 6-9

Washington, DC 20549

Re: File No. S7-5-99

Dear Secretary Katz,

I would like to express my concern over the Reproposal of Amendments to Rule 15c2-11 and its effect on our ability to finance the current and future growth of our company. I urge you to block the adoption of this rule.

Sincerely,

Michael D. Dunham

President

cc: Commissioner Arthur Levitt

Chairman Isaac C. Hunt, Jr.

Norman Johnson

Paul R. Carey

Laura Simone Unger