Subject: Rule 15c2-11; a better way - the intermediate private-sector

Date:    01/19/2000 7:41 PM
     
     
Obviously, the primarily responsible investing community has no use for the 
Rule 15c2-11 proposals.
     
I find a lot of their arguments have merit, and the "chop shops" and 
swindlers will have no respect for the regulation to begin with.
     
Would it not seem more practical to include an intermediadate tier of SEC 
approved and independent CPAs, who are payed by the SEC (which would derive 
the funding by application fees).  The Class-SEC (at-arms-length) CPAs would 
review all applicants for public trading (Pink, BB, or otherwise) and both 
certify and follow the activities of the applicants - removing this burden 
from the Market Makers.
     
No Class-SEC (at-arms-length) CPAs  approval, no MM, not quotes, no 
trading......
     
If there are violations of this system, the Class-SEC (at-arms-length) CPAs 
and the slimeoid CEO both get sentenced to the Government funded Milken 
golf-club.  And, it's a one-time, one-screw-up deal.  You don't ever come 
back to trade or work in the system if you foul-up.
     
"0"-tollerence, no "..Uncle Alan [Greenspan].." want's him to have another 
chance...!!
     
In electrical construction, you only hire a bonehead/thief once..!!  In the 
military you only violate your secrecy agreement once.  Is there some reason 
that philosophy won't work in the Securities Business..??
     
A response would be appreciated.
     
Respectfully,
     
John M. Hollen, EE