METROPOLITAN CAPITAL ADVISORS, INC.

660 Madison Avenue, New York, NY 10021

November 25, 1998

Mr. Jonathan G. Katz

Secretary

Securities and Exchange Commission

450 Fifth Street, NW

Washington, DC 20549

Re: File no. S7-12-98

Dear Mr. Katz:

I am writing to comment on the above referenced proposed Regulation on Alternative Trading Systems ("ATS"). As senior equity trader at Metropolitan Capital Advisors, Inc. ("MCA"), I have concerns regarding the proposed changes that will force me to publicly display my orders on the NASDAQ quote stream.

MCA’s investors benefit from the choices that are available to get the best execution. An important choice is whether or not to publicly display my orders. Choosing not to publicly display my orders enables me to protect my trading strategy and efficiently and anonymously execute my trades.

In summary, requiring the display of these orders would limit my ability to achieve efficient, anonymous and low cost execution.

Sincerely,

Tracy Altebrando

Senior Equity Trader