Subject: Re. File No. S7-5-99
Author:  "Gratian M. Yatsevitch; III" <ismc@erols.com> 
Date:    4/7/99 4:49 PM
     
     
In reference to the proposed amendments to Rule 15c2-11, I am strongly 
against the idea that market makers should serve as regulators in any 
way, and thereore the proposed change in the rule.  Such a change in the 
rule, I believe, would inhibit market makers in their function and make 
it far harder for small Bulletin Board traded companies such as my own 
to access capital.
     
The system that is presently in place serves the market pretty well and 
I think that the new rule relating to Rule 504 will help in discouraging 
illegal practices.
     
Sincerely yours,
     
Gratian M. Yatsevitch, III
Exec. Vice President
International Shoe Manufacturing Corp.