Intellivest Securities, Inc. 
                                           P.O. Box 162487
                                           Atlanta, GA. 30321-9998
     
     
                             March 22, 1999
     
Jonathan G. Katz, Esq.
Secretary
Mail Stop 0609
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC  20549-0609
     
Re:  Proposed Rules 15b7-2 and 17Ad-20 and temporary Rules 15b7-3T, 17Ad-21T 
and 17a-9T under the Securities Exchange Act of 1934
     
Dear Mr. Katz:
     
There are approximately 4,300 broker-dealers that will be covered under the 
proposed rules.  A review of the Securities Industry Association handbook 
reveals that the vast majority of these broker-dealers have net capital less 
than $1,000,000.  It is respectfully submitted that the new rules not apply to 
those broker-dealers who have less than a certain number of retail clients, 
say 500., who are introducing broker-dealers, and have required net capital 
less than $250,000.   In the alternative, since much of the basis of the 
Commission's action is based on fraud concerns, the broker-dealers should have 
the right to notify clients of the inherent risks of being non-YK2 compliant. 
This disclosure should dispense with the requirement of adhering to the 
proposed rules.  In addition, introducing firms should be able to send a 
letter to clients stating the readiness level of their clearing firm.  Market 
forces should be adequate motivation to be YK2 compliant.  Thank you.
     
                                                        Respectfully
							submitted,
     
     
                                                         Daniel H. Kolber
                                                         General Counsel