To: Office of Management and Budget
Attn: Desk Officer for the Securities Exchange Commission
Regarding: File No. S7-8-99
From: Mary Jo Rump, Y2K Project Manager, Securities America, Inc
Date: April 12th, 1999

This correspondence is in response to the request for comment for File No. S7-8-99. 
Jeffrey Schwartz of the SEC's Division of Market Regulation was a presenter at the 11th 
Hour Contingency Planning Seminar in March.  At the conclusion of Mr. Schwartz's 
presentation he encouraged those of us in attendance to send out comments concerning 
these temporary rules.

Securities America, Inc is a fully disclosed broker dealer in Omaha Nebraska.  Securities 
America uses National Financial Services Corporation as our clearing firm to maintain 
our client data and process our trades.

The 17b7-2 rule has designated that August 31, 1999 will be the date used to determine if 
a broker/dealer will have operational capability.  As a fully disclosed firm our operational 
capability is dependent on NFSC’s operational capability. SAI would like to see the 
August 31, 1999 date to be used for those firms that clear the trades like National 
Financial Services Corporation and other transfer agents. 

Yet another date should be proposed for those fully disclosed broker/dealers that would 
be used to insure that they have time to select another clearing firm and move their 
accounts to the new firm.  Concern exists that if a Clearing firm was informed to cease 
business would affect our clients ability to manage their holdings in the time frame that it 
takes to transfer the accounts to the new clearing firm and to get access to the new firm’s 
Information systems.  The Clearing firms that have been identified as being unable to 
meet the date handling deadline must insure that they will continue processing business 
until the last of their clients (broker/dealers) have moved all of their accounts.

If Clearing firms are allowed to wait until October 15th, 1999 before finally 
acknowledging that they are unable to correct their data handling routines in their 
Information systems, there will be limited amount of time for the Year 2000 compliant 
clearing firms to absorb any new clients.