Subject: Proposed Rule 701;  File No. S7-5-98
Date:    4/30/98 4:50 PM
     
To:  Mr. Jonathan G. Katz, Secretary, SEC
     
Dear Mr. Katz:
     
As Chief Financial Officer representing the owners of a medium sized private 
U.S. corporation, I would like to add my endorsement for the proposed 
revisions to Rule 701.
     
The current $5 million annual limit on securities offered  to employees 
limits our ability to offer our company stock to a broader group of 
employees, causing us to restrict employee ownership to a small number of 
senior employees.  The proposed new limitations would allow companies like 
ours to increase employee ownership while ensuring the protection of the 
employee investor. 
     
We encourage the Commission to implement the proposed revisions immediately 
after the comment period ends.
     
     
Sincerely,
John W. Argent
Senior Vice-president & Chief Financial Officer 
Basic American, Inc.
2999 Oak Road, Walnut Creek, Ca. 94596
     
E-Mail:  jargent@baf.com