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            The Chase Manhattan Bank                            David M. Morris
            52 Broadway, 3rd Floor                              Financial Director
            New York, NY 10004
            Tel  212-701-7007
            Fax 212 701-7044
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                                                          July 27, 1997

         Mr. Jonathan G. Katz, Secretary
         U.S. Securities and Exchange Commission
         450 Fifth Street, N.W.
         Washington, D.C. 20549
         File No. S7-17-98

         Dear Mr. Katz:

          The Chase Manhattan Corporation (Chase) is pleased to submit its comments on the
          Securities and Exchange Commissions ( SEC's) proposed technical amendments
          (Proposed Rule Changes) regarding its segment reporting requirements (Items 101
          and 102 of Regulation S-K, Rules 3-03 and 12-16 of Regulation S-X and Schedule
          14A and Form 20-F and Sections 501.06 and 503 of the Codification of Financial
          Reporting Policies).

          Chase generally supports the Proposed Rule Changes and agrees that the SEC should
          conform its segment reporting requirements to the Financial Accounting Standards
          Board's (FASB's) recently issued Statement of Financial Accounting Standards No.
          131, Disclosures About Segments of an Enterprise and Related Information (SFAS
          131).

          In response to your specific request, we believe the SEC's proposal should not
          maintain the quantitative thresholds (generally 10% or greater of consolidated
          revenue) of Item 101(c)(1)(i) and should follow the requirements of SFAS 131.
          SFAS 131 requires that an enterprise provide entity-wide disclosure of revenues
          from external customers for each product and service or each group of similar
          products and services (only if it is not provided as part of the reportable
          operating segment information required by SFAS 131), unless it is impracticable
          to do so.  Since the SEC's goal is to comform to SFAS 131, we see no benefit,
          only process burden, from establishing another quantitative threshold.

          In addition, we believe that Item 102 should omit the reference to what
          "segments"  use the described properties.  Such disclosure is not a requirement
          of  SFAS 131 and, therefore, should not be required.

          We would be pleased to discuss our comments with you at your convenience.  If you
          have any questions, please contact me at 212-701-7007.



         Very truly yours,


                                                                                                              /s/
         David M. Morris