ONLINE TRADING INC.
          2650 N. Military Trail, Suite 125
          Boca Raton, FL 33431
       
          August 6, 1998

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

        
                          Re: File No. S7-7-98

          Dear Mr. Katz:

          Online Trading Inc. ("Online") is a fully disclosed NASD Member Firm having a
          minimum net capital requirement of $100,000.  Online believes that by forcing
          NASD member broker/dealers to engage an independent public accountant to attest
          to the specific assertions in the required Y2K reports sends is a poor idea for
          several reasons:

          1. It assumes that the engaged accountant knows more about information systems
          than the broker/dealer's own management. 2. It sends a negative message
          conveying a lack of trust and confidence in reports provided to regulators by
          senior management of broker/dealers. 3. It assumes that the management of the
          broker/dealer is not concerned about the Y2K problems and its ability to
          properly service its clients. 4. It creates unnecessary expenditures in
          professional services which instead could be applied towards new software and
          hardware to directly address the Y2K problem.
          5. The larger the broker/dealer the more it stands to lose with Y2K problems and
          the more likely it is to have internal staff capable of effectively addressing
          Y2K problems internally.

          I firmly believe in the Y2K status reports required by the SEC and the NASD;
          however, for the reasons listed above, forcing firms to independent attestation
          of these reports seems unnecessary and unproductive.

          I can be reached at 800-995-1076 if you wish to discuss this further.

          Sincerely,

          E. Steven zum Tobel, CPA
          CCO & CFO