Date:    8/7/98  4:28 PM
       
          Asset Management Securities Corp.
          40 SE 5th Street, Suite 600
          Boca Raton,  FL  33432

          NASD CRD # 14433

          August 7, 1998

          Jonathan G. Katz, Secretary
          Securities & Exchange Commission
          450 Fifth Street, NW
          Washington, DC  20549

         
          RE:  File S7-7-98

          Dear Mr. Katz,

          Asset Management Securities Corporation is a fully disclosed NASD member firm
          having a minimum net capital requirement of $50,000.  Our primary source of
          revenue is from the sale of mutual funds and variable annuities.
           We clear some of these through a clearing firm, while the majority is processed
          by application directly with the fund companies.  The only reason our net
          capital is $50,000 is because we service our clients by taking securities
          certificates from clients and promptly transmit to our clearing firm.   Although
          as a business, as well as a broker dealer, we are in the throws of ensuring that
          we will be able to move into the Year 2000 without difficulty, much of our
          brokerage business is dependent on the clearing firm or the funds companies'
          compliance with Y2K.  Therefore it would be a great waste of time and money for
          us to be required to have our auditors attest to the specific assertions of the
          required Y2K reports.  In addition, to the cost of such a report, I believe we
          as broker/dealers would be paying for our auditing firms to actually learn the
          specifics of Y2K compliance.  I have in the past seen many instances were
          broker/dealers are bearing the expense to train outside consultants and auditors
          to understand our business.  We believe that our time and money could be better
          spent training our internal MIS department and purchasing and implementing the
          use of new hardware and software that is Y2K compliant.

          Finally, if there are any broker/dealers that should be required to be audited,
          it should be the ones that fully disclosed broker/dealers are going to be
          relying on to be ready for the Year 2000.  If clearing firms and funds companies
          and other custodial broker/dealers are not Year 2000 ready, the snowball effect
          on all of us would be tremendous.

          I thank you for your time and consideration of this matter.  Should you have any
          questions, please call me at 561-368-9120.

          Very truly yours,


          Jennifer K. Aracri
          Vice President and FINOP