Irvington, NY 10533

(914) 591-5800

Fax (914) 591-5810

6 May, 1999

RE: File No. S7-5-99

This firm does not have any customers nor does it work on orders for other broker-dealers. We trade in a small number of non-Nasdaq or non-exchange listed securities hoping to make a profit on increases in the value of our inventory. After consultation with our lawyer we have decided that if the proposal is adopted, we must no longer make a market in these securities because of the risk of being swept into a lawsuit.

Two of these Bulletin Board securities in which we make a market are derivatives of a security that is a Nasdaq NMS security, EMCG i.e., Emcor Group. We believe that EMCG is a security that would qualify to be a "Securities excluded from the Rule" were it not traded on Nasdaq. We believe that derivatives of "Securities excluded from the Rule" should also be exempt from the rule. We also believe that derivatives of securities traded on Nasdaq or on an exchange probably should also be exempt from the rule.

Sincerely yours,