April 27, 1999

JONATHAN G KATZ, SECRETARY
THE SECURITIES AND EXCHANGE COMMISSION
450 FIFTH STREET, NW
WASHINGTON DC 20549

 SUBJECT: FILE No. S7-11-99

     Revised Transfer Agent Form and Related Rule

Dear Mr. Katz:

   I am writing in regards to the proposal to amend Form TA-2, specifically as it relates to the number of lost securityholders on our records.

   As a result of Rule 17Ad-17, we are conducting searches twice each year to determine the correct addresses of all of our lost shareholders. Our search agent reports to us the number of accounts found from each search. Keep in mind that each search that is conducted is a first search for some accounts and a second search for others. When a shareholder is located, the search firm mails a confirmation letter to the shareholder. If the shareholder chooses to respond, they are asked to return the confirmation letter, but it is not uncommon for our shareholders to call us and change their address over the phone without mentioning the fact that they had received a confirmation letter.

   Our concern is that once a "lost" shareholder contacts us, it would be difficult to determine if a shareholder is changing their address as a result of a search, or even more specifically, if the contact is as a result of a first or second search. In addition, our present shareholder software system does not have a field to capture the dates of a first and second search.

   Since we anticipate difficulty in reporting accurate numbers of search results, perhaps it would be better to ask for the dates of the searches to ensure that the transfer agent is in compliance with the rule; and also the total number of "located" accounts for searches conducted during the Form TA-2 reporting period.

   We respectfully request that you consider our comments to the proposed change.

       Sincerely,

       James R. Alden
       Manager and Assistant Secretary
       Shareholder Services