Subject: SR-NASD-98-21
Date:    4/13/98 6:09 PM
     
     
The actual size rule is just another attempt by the NASD market making 
community to widen the "effective spread" of NASDAQ stocks. It was too 
obvious what they where doing before: 1. quoting in only eighths and 
quarters  2. keeping huge spreads in even the high volume NASDAQ stocks  3. 
not displaying competing quotes. 
     
If you let them get away with this most recent proposal, everything Arthur 
Levit has accomplished for us (the small investor) will be lost. The actual 
size rule allows them to go back to very old tricks:  1. quoting prices 
that are not real (except 100 shares)  2. to move the NASDAQ stocks around 
at will because they will now be able to back away at will.
     
If you look at all the highlights of their proposal: 
1. handling a phone order
2. minimum quote of 100 shares
3. closing quotes for 3 minutes
4. 10 second cancellations
5. 17 seconds to adjust quotes
     
All these are about the same thing: ability to back away from quotes thus 
widening the "effective spread". The effective spread becomes very wide 
when you don't have to honor your quotes.
     
Please do not undo everything the S.E.C. has accomplished the last few 
years by approving this NASD proposal. Your job is to protect us from this 
fraud.
     
George Kiefer
kiefer@jump.net
512-231-8256
7700 N. Capital TX Hwy #1111
Austin, TX  78731