Subject: SEC Comment Author: Date: 4/27/99 4:16 PM File No. S7-8-99 Mr. Katz: I have just complete my Year 2000 report for the most recent period, and have finally after completing my annual audits, my corporate tax returns, my personal tax return, my quarterly FOCUS reports, I had a chance to read the most recent proposed rules. I realize it is past the deadline for commenting. But I think some of the above were more important. One item in the proposed rules that is of great concern it the fact that a Broker/Dealer would be presumed to have a material Year 2000 problem (and would therefore be presumed to not be operationally capable) if, at any time on or after August 31, 1999, it: does not have written procedures to identify, assess, and remediate any Year 2000 problems in its mission-critical systems. This might be fine for a large broker/dealer, bur for a small B/D (one in which there is only one owner/officer) is it really necessary to deem us non operational. I realize the intent is for the larger firms were they my be incapable of making decisions without having several committee meeting and management approval. I see too much room for abuse for our self regulatory agencies to go after small firms which do not have the need or the time to write yet another written report. I think the SEC, whose purpose is, "...for administering the federal securities laws. The purpose of these laws is to protect investors in securities markets that operate fairly and to ensure that investors have access to disclosure of all material information concerning publicly traded securities. The Commission also regulates firms engaged in the purchase or sale of securities, people who provide investment advice, and investment companies..." should not continue to create rules which provide an undue burden upon smaller firms who actually know their customers. Kevin P. Biber President Greentree Investment Services, Inc.